Summary
The United States District Court for the Southern District of Indiana denied Lakesha Mitchell’s petition for a writ of habeas corpus challenging a prison disciplinary conviction for trafficking contraband. The court held that the disciplinary decision was supported by some evidence, that the equal protection claim lacked evidence of intentional discrimination, and that the exculpatory statement of another inmate did not require relief.
Court
United States District Court for the Southern District of Indiana
Jurisdiction
United States District Court for the Southern District of Indiana
Decision date
December 16, 2025
Docket number
2:24-cv-00035-JPH-MKK
Disposition
dismissed
Questions Presented
- Whether the disciplinary sanction violated the Equal Protection Clause because another inmate allegedly received a lesser classification and sanction for a trafficking offense.
- Whether the disciplinary conviction was supported by some evidence that Mitchell possessed or transferred the contraband in the green sweatshirt.
- Whether Jennings's statement accepting ownership of the tobacco required vacatur of Mitchell's disciplinary conviction.
Holdings
- Mitchell was not entitled to habeas relief on her equal protection claim because she presented no evidence that the different offenses and sanctions resulted from intentional discrimination based on a protected class.
- The disciplinary conviction satisfied due process because the conduct report supplied some evidence from which a reasonable inference could be drawn that the tobacco was in the sweatshirt when Mitchell possessed and transferred it.
- Jennings's statement that she owned the tobacco and that Mitchell lacked knowledge of it did not require vacatur of Mitchell's conviction because the disciplinary hearing officer was not required to credit that statement over the other evidence.
Court Document
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