Background
Juan Zapata, a federal prisoner, filed a petition under Section twenty-eight United States Code, Section twenty-two forty-one, challenging a disciplinary hearing officer’s finding that he possessed a hazardous tool, specifically a cellphone. The disciplinary officer revoked Zapata’s good conduct time based on this finding. The district court accepted a magistrate judge’s recommendation and denied relief, leading to this appeal.
The court’s reasoning
The court reviewed the district court’s denial de novo and applied the ‘some evidence’ standard established in Superintendent, Mass. Corr. Inst. v. Hill. This standard is exceedingly lenient and requires only a modicum of evidence to prevent arbitrary deprivations. The court found that the officer’s written report, Zapata’s statement, a photograph of the phone, and his disciplinary record established that he constructively possessed the phone. Consequently, there was sufficient evidence to support the revocation of good conduct time.
We review the district court’s denial of habeas corpus relief de novo.
Valladares v. Ray, 130 F.4th 74, 80 (4th Cir. 2025)
What it means going forward
The decision reinforces the deferential ‘some evidence’ standard applied in federal prison disciplinary proceedings, making it difficult for inmates to overturn good conduct time revocations when minimal evidentiary support exists in the record.