Santiago Soto-Garcia v. Warden Ian Healy

Summary

The court denied a federal inmate’s 28 U.S.C. § 2241 petition challenging a disciplinary finding for fighting another person and the resulting loss of good-time credits. The court held that the disciplinary proceedings satisfied due process and that the finding was supported by some evidence, including surveillance footage, medical records, photographs, and the petitioner’s statements. The action was dismissed, and the court certified that an appeal could not be taken in good faith.

Holdings

1. The disciplinary hearing satisfied due process because Soto-Garcia received written notice before the hearing, had an opportunity to present documentary evidence and to call witnesses, and received a written DHO report explaining the evidence relied upon and the reasons for the disciplinary action.
2. The DHO's finding that Soto-Garcia fought another person was supported by some evidence and therefore complied with due process.
3. The court could not reweigh the evidence, reassess credibility, or substitute its judgment for the DHO's determination regarding self-defense.

Questions Presented

1. Whether the disciplinary hearing violated due process because Soto-Garcia allegedly did not receive adequate notice, an adequate opportunity to present a defense, or a written statement of the evidence and reasons supporting the sanction.
2. Whether the DHO's finding that Soto-Garcia fought another person was supported by some evidence.
3. Whether the district court could reconsider the DHO's self-defense analysis, credibility determinations, and weighing of the evidence.

Disposition

dismissed