A man who killed a guard and nurse in a 2021 breakout attempt at an Iowa prison has the right to contest being held in solitary confinement, a federal appeals court says.
The decision by the Eighth U.S. Circuit Court came in the case of Michael Dutcher, who was charged with fellow inmate Thomas Woodard Jr. in the bloody attempt to escape from Anamosa State Penitentiary. They pleaded guilty in the bludgeoning deaths of corrections officer Robert McFarland and prison infirmary nurse Lorena Schulte.
The pair also seriously injured a fellow detainee and briefly held hostage a third prison worker in the March 2021 violence.
Convicted of first-degree murder, Dutcher and Woodard, who were serving terms for armed robbery at the time of their escape attempt, were sentenced to life in prison. Court records show officials agreed to have Dutcher serve his sentence in Missouri prisons under the Interstate Corrections Compact, which allows for transfers between state prison systems.
Woodard, likewise, was allowed to serve his term in his home state of Nebraska.
Dutcher has filed a number of lawsuits challenging aspects of his Missouri confinement. In the appeals court case, he alleged he had been held in administrative segregation, or solitary confinement, since his arrival.
He claimed prison officials repeatedly had recommended and affirmed he remain there and told him it was because of his “Iowa conduct history.” He said one warden allegedly told him, “You’re in Ad Seg because that’s where I want you. Because of what you did in Iowa, I have absolutely no intention of ever letting you out of Ad Seg.”
A Missouri federal judge dismissed Dutcher’s lawsuit in February 2025, finding that, even if Dutcher does have due process rights in connection with his solitary confinement, Missouri prison officials had met those rights by holding multiple review hearings in which they reaffirmed his placement. The judge also noted Dutcher has accumulated numerous disciplinary violations while in Missouri custody, including making threats.
The Monday, April 13, appellate decision reverses that ruling. In its unsigned opinion, the court found Dutcher had shown a possible violation of his rights.
“We conclude that, at this early stage, Dutcher adequately stated a due process claim based on his prolonged placement in ad seg without meaningful review, as he alleged that prison officials told him the outcomes of his periodic reviews were predetermined and that he would never be removed from (administrative segregation) because of his actions while incarcerated in (Missouri), regardless of his behavior,” the court wrote.
The decision does not mean Dutcher has a right to be released from solitary confinement. But it returns his lawsuit to the lower court to determine whether Missouri had in fact failed to give Dutcher a fair hearing.
Dutcher does not have an attorney listed to represent him. The Missouri Attorney General’s Office did not respond to a message inquiring about the decision.
The killings at Anamosa, which Dutcher and Woodard carried out with tools obtained from a locker for a work detail they served on, led to a third-party review of the more than 150-year-old prison. Changes included the demotion and replacement of the warden and the reduction of Anamosa’s security rating to medium from maximum.
The state also sought to bolster prison staffing, which a Des Moines Register investigation found had fallen to a 30-year low after rounds of budget cuts.
William Morris covers courts for the Des Moines Register. He can be contacted at wrmorris2@registermedia.com or 715-573-8166.
This article originally appeared on Des Moines Register: Life‑sentenced Anamosa inmate can challenge long‑term solitary confinement
Reporting by William Morris, Des Moines Register / Des Moines Register
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