Background
Federal prisoner Christopher Williams appealed pro se from a district court order denying his petition for a writ of habeas corpus under Section twenty-eight U.S.C. two thousand two hundred forty-one. Williams challenged a prison disciplinary proceeding, arguing that his procedural due process rights were violated because he was not provided with the Disciplinary Hearing Officer’s written report in a timely manner.
The court’s reasoning
The panel reviewed the case de novo and noted that the record indicated the Disciplinary Hearing Officer’s report was delivered to Williams seven days after his hearing and again during the administrative review process. The court stated that even if Williams did not timely receive the report, he has not established what collateral consequences or fundamental constitutional rights may have been abridged as a result. The court cited Wolff versus McDonnell, noting that Williams failed to demonstrate a constitutional violation. Regarding the request for an evidentiary hearing, the court concluded one was not required because the record conclusively shows that Williams is not entitled to habeas corpus under Section twenty-eight U.S.C. two thousand two hundred forty-one.
the record conclusively shows that [Williams] is not entitled to habeas corpus under 28 U.S.C. § 2241
Anderson v. United States, 898 F.2d 751, 753 (9th Cir. 1990)
What it means going forward
The decision reinforces that federal prisoners must demonstrate specific collateral consequences or abridged fundamental rights to succeed on habeas challenges regarding prison disciplinary procedures. It also clarifies that evidentiary hearings are unnecessary when the existing record conclusively shows the petitioner is not entitled to relief.
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