Sean Stone v. Warden

Summary

The United States District Court for the Northern District of Indiana denied Sean Stone’s habeas corpus petition challenging a prison disciplinary conviction for possessing a cell phone. The court held that Stone received adequate notice and procedural protections, that some evidence supported the conviction, and that the alleged deficiencies concerning evidence, lay advocacy, and impartiality did not establish a due process violation.

Holdings

1. An alleged failure to comply with the Indiana Department of Correction's internal screening deadline does not provide a basis for federal habeas relief because federal habeas relief is unavailable for errors of state law or prison policy absent a federal constitutional violation.
2. Stone was not denied due process because the requested witness statement was obtained and considered, and the requested surveillance and body-camera footage did not exist.
3. Stone received constitutionally adequate notice because he was notified more than 24 hours before the hearing and the conduct report identified the charged rule and summarized the facts supporting the charge.
4. The disciplinary conviction was supported by some evidence and therefore satisfied due process.
5. Stone's dissatisfaction with his lay advocate did not establish a due process violation because a lay advocate is constitutionally required only when the inmate is illiterate or the case is unusually complex, and neither condition was present.
6. The hearing officer was not shown to be impermissibly biased because the record did not indicate substantial involvement in the underlying incident, and declining to credit a witness's statement did not establish bias.

Questions Presented

1. Whether alleged untimely screening under the Indiana Department of Correction disciplinary code warranted federal habeas relief.
2. Whether Stone was denied due process through the absence of a purported additional witness statement or unavailable surveillance and body-camera footage.
3. Whether Stone received constitutionally adequate notice of the disciplinary charge.
4. Whether some evidence supported the disciplinary finding that Stone possessed a cell phone.
5. Whether the performance of Stone's lay advocate violated due process.
6. Whether the hearing officer was impermissibly biased and denied Stone an impartial decisionmaker.

Disposition

dismissed