Quiroz v. Allen

Summary

The United States District Court for the Southern District of Indiana denied Eriberto Quiroz's petition for a writ of habeas corpus under 28 U.S.C. § 2254. The court held that the prison disciplinary proceeding, which resulted in a 30-day loss of good-time credits for engaging in an unauthorized financial transaction, satisfied due process requirements. The court also denied Quiroz's motion to strike video evidence and directed entry of final judgment.

Holdings

1. Any assumed error in denying Quiroz the opportunity to present Murphy's testimony was harmless and did not warrant habeas relief because the proposed testimony would not have undermined the conduct report or created a reasonable probability of a different result.
2. The court could not grant federal habeas relief based on Quiroz's contention that he did not violate Offense 220 because he did not answer Murphy's question; that argument would require the federal court to disagree with prison officials' interpretation of state law.
3. Quiroz was not denied due process by the failure to provide Officer Carson's body-camera footage because he offered no evidence that the footage existed, and prison administrators are not required to produce evidence they do not possess.
4. The motion to strike the respondent's video exhibit was denied because the asserted prejudice concerned an unrelated food-tray issue and the video was neither misleading nor unfairly prejudicial.

Questions Presented

1. Whether denial of Murphy's proposed witness testimony violated Quiroz's due process right to present material and exculpatory evidence in the prison disciplinary proceeding.
2. Whether failure to provide or preserve body-camera video and audio violated Quiroz's due process rights.
3. Whether the disciplinary hearing officer's interpretation of Indiana prison Offense 220 provided a basis for federal habeas relief.
4. Whether the respondent's video exhibit should be stricken as misleading or unfairly prejudicial.

Disposition

dismissed