Blanc v. Taylor

Summary

The document is a magistrate judge’s findings and recommendation in a federal prisoner’s 28 U.S.C. § 2241 habeas petition challenging prison disciplinary proceedings. It recommends granting the respondent’s motion to dismiss because the alleged UDC deficiencies and delayed receipt of the DHO report did not state a cognizable due process or habeas claim.

Holdings

1. The petition failed to state a cognizable due process claim based on alleged deficiencies in the UDC process because the UDC cannot revoke an inmate's good-conduct-time credit and therefore its proceedings did not deprive Blanc of a protected liberty interest.
2. Blanc failed to state a cognizable due process claim concerning the DHO report because the undisputed record showed that he was provided a copy of the report, and the alleged delay did not deprive him of the constitutional process required by Wolff.

Questions Presented

1. Whether alleged defects in the Unit Discipline Committee process stated a cognizable due process claim under § 2241 when the UDC could not revoke good-conduct-time credit.
2. Whether an alleged delay or failure to provide a DHO report stated a cognizable federal due process or habeas claim when the record showed that the report was ultimately provided.
3. Whether noncompliance with the deadline in a BOP program statement, without a violation of the constitutional minimum procedures required by Wolff v. McDonnell, supports § 2241 habeas relief.

Disposition

dismissed