Christopher Coats v. Warden

Summary

The United States District Court for the Northern District of Indiana dismissed Christopher Coats's habeas corpus petition challenging a prison disciplinary conviction because the proceeding did not lengthen the duration of his confinement. The court also directed the clerk to close the case and denied Coats leave to proceed in forma pauperis on appeal.

Holdings

1. A prison disciplinary action may be challenged in a habeas corpus proceeding only when it results in the lengthening of the duration of confinement. Because Coats received neither a loss of earned credit time nor a demotion in credit class, his disciplinary proceeding did not lengthen his confinement and was not cognizable in habeas corpus.
2. A habeas corpus petition must be dismissed under Section 2254 Habeas Corpus Rule 4 when it plainly appears from the petition and attached exhibits that the petitioner is not entitled to relief.
3. A certificate of appealability was not required because Coats was challenging a prison disciplinary proceeding.
4. Coats could not proceed in forma pauperis on appeal because an appeal could not be taken in good faith.

Questions Presented

1. Whether a prison disciplinary proceeding is cognizable in federal habeas corpus when it does not lengthen the duration of the prisoner's confinement.
2. Whether the petition should be dismissed at screening under Section 2254 Habeas Corpus Rule 4.
3. Whether a certificate of appealability is required to appeal the decision and whether Coats may proceed in forma pauperis on appeal.

Disposition

dismissed