Andre Moton v. Allen Warden

Summary

The United States District Court for the Southern District of Indiana denied Andre Moton's petition for a writ of habeas corpus challenging an Indiana prison disciplinary conviction and sanctions. The court rejected claims concerning pre-hearing confinement conditions, impartiality of the disciplinary hearing officer, mental-health considerations, appointment of counsel, and double jeopardy. The action was dismissed with prejudice.

Holdings

1. An alleged violation of state prison policy does not state a cognizable federal habeas claim, and Moton failed to show that the pre-hearing restrictions deprived him of material, exculpatory evidence or impaired his defense.
2. Moton failed to establish that the disciplinary hearing officer was impermissibly biased; the presumption of honesty and integrity therefore prevailed.
3. Due process did not require consideration of Moton's mental-health issues as a separate condition of the disciplinary proceeding, prohibit the sanctions imposed, or provide appointed counsel instead of a lay advocate.
4. Moton's double-jeopardy claim failed because placement in a strip cell was an administrative decision and prison discipline is a noncriminal proceeding to which double jeopardy does not apply.

Questions Presented

1. Whether Moton's alleged placement in a strip cell and deprivation of research materials and law-library access before the disciplinary hearing violated federal due process or supplied a basis for habeas relief.
2. Whether the disciplinary hearing officer was impermissibly biased or lacked impartiality because Moton had been placed in a strip cell before the hearing and was later sanctioned.
3. Whether Moton's mental-health issues required different disciplinary sanctions or appointment of counsel rather than a lay advocate.
4. Whether the disciplinary proceeding and sanctions subjected Moton to double jeopardy.

Disposition

dismissed