Joshua Brereton v. Eric Rardin

Summary

The United States District Court for the Eastern District of Michigan denied Joshua Brereton’s petition for a writ of habeas corpus under 28 U.S.C. § 2241. The court held that the disciplinary proceeding satisfied due process requirements and that sufficient evidence supported the finding that Brereton assaulted another inmate, resulting in the loss of good conduct time. The court also rejected claims concerning alleged defects in the Bureau of Prisons’ administrative-remedy process.

Holdings

1. The disciplinary proceeding satisfied the minimum procedural due process requirements because Brereton received advance written notice, an opportunity to call witnesses and present documentary evidence, an offer of staff assistance, and a written statement of the evidence relied on and the reasons for the sanction.
2. The loss of good conduct time was constitutionally permissible because some evidence, and in fact abundant evidence, supported the DHO's finding that Brereton assaulted another inmate.
3. Alleged defects in the Bureau of Prisons administrative-remedy process did not entitle Brereton to habeas relief or establish a due process violation.

Questions Presented

1. Whether the Bureau of Prisons disciplinary proceeding violated procedural due process because Brereton allegedly was denied a meaningful opportunity to present witnesses and documentary evidence.
2. Whether sufficient evidence supported the DHO's finding that Brereton assaulted another inmate and the resulting loss of good conduct time.
3. Whether alleged defects in the Bureau of Prisons administrative-remedy process independently violated Brereton's due process rights or entitled him to habeas relief.

Disposition

denied