Reported / Citable
Background
Federal prisoner Alexis Arriaga petitioned under 28 U.S.C. § 2241 to challenge a Bureau of Prisons disciplinary proceeding. The incident report charged him with possessing a hazardous tool after officers found eight cellphones and eight chargers, wrapped in a pillowcase and duct tape, in the air vents of his cell at FMC Fort Worth.
Arriaga denied that the contraband was his. He said he had moved into the cell about a month and a half earlier and that his cellmate had accepted responsibility. The disciplinary hearing officer nevertheless found the charge supported and imposed sanctions.
The Court’s Holding
The court denied the petition. It held that the disciplinary process satisfied the procedural protections required by Wolff v. McDonnell: Arriaga received notice, had an opportunity to present evidence and request assistance, and received written findings explaining the decision.
The court also held that the record contained the required “some evidence” supporting the guilty finding. The contraband was found in Arriaga’s cell, and the court concluded that this supported constructive possession. Arriaga’s rights were read to him in Spanish, and he waived the staff representative and witness he had initially requested.
Key Takeaways
- A federal court does not retry prison disciplinary disputes on a § 2241 petition.
- Due process is satisfied when the inmate receives the required notice, opportunity to present evidence, and written decision.
- Contraband found in an inmate’s cell can supply sufficient evidence for a constructive-possession finding.
Why It Matters
The decision illustrates the narrow scope of federal habeas review of BOP disciplinary rulings. Once required procedures are provided, a disciplinary finding will stand if the record contains some evidence supporting it, even where the inmate offers an alternative explanation for the contraband.