Juan Zapata, a federal prisoner, filed a petition under 28 U.S.C. § 2241 in the United States District Court for the District of South Carolina. He challenged a disciplinary hearing officer's finding that he possessed a hazardous tool, specifically a cellphone, which resulted in the revocation of his good conduct time. The district court accepted a magistrate judge's recommendation and denied relief. Zapata appealed, arguing that the evidence supporting the disciplinary finding was insufficient to satisfy due process requirements.
The Fourth Circuit reviewed the district court's denial of habeas corpus relief de novo. The court reiterated that a finding of guilt in a prison disciplinary proceeding must be supported by 'some evidence,' a standard established in Superintendent, Mass. Corr. Inst. v. Hill. The court described this as an 'exceedingly lenient standard' that requires only a modicum of evidence to prevent arbitrary deprivations without threatening institutional interests. The court clarified that determining whether this standard is met does not require an independent assessment of witness credibility or a weighing of the evidence. Instead, the inquiry is limited to whether there is any evidence in the record that could support the disciplinary hearing officer's conclusion. The court emphasized that for evidence to be distinguished from no evidence, it must possess at least some minimal probative value to satisfy the Due Process Clause. Upon reviewing the record, the court concluded that the officer's written report, Zapata's statement during the hearing, a photograph of the phone, and Zapata's disciplinary record collectively established that he constructively possessed the phone. Therefore, the 'some evidence' standard was satisfied.
The district court's order denying relief remains in effect, and Zapata's sentence stands without the restoration of the revoked good conduct time. The decision reinforces the high bar for federal prisoners challenging disciplinary findings, confirming that the 'some evidence' standard is easily met when there is a minimal factual basis, such as a report, a statement, and a photograph, linking the prisoner to the contraband.