Marcus Richardson v. Emerson

Summary

The United States District Court for the Southern District of Indiana denied Marcus Richardson’s petition for a writ of habeas corpus challenging a prison disciplinary conviction and loss of good-time credit. The court held that the conduct report and video summary provided some evidence supporting the finding that Richardson battered another incarcerated person, and that self-defense is not a constitutionally required defense in prison disciplinary proceedings. The action was dismissed with prejudice and final judgment was directed.

Holdings

1. The disciplinary conviction satisfied due process because the conduct report and video summary constituted ample evidence that Richardson battered another inmate.
2. An inmate does not have a constitutional right to raise self-defense as a defense in a prison disciplinary proceeding.
3. The court may not reweigh the evidence underlying a disciplinary decision or determine whether other record evidence supports a contrary finding once some evidence supports the conviction.

Questions Presented

1. Whether the prison disciplinary conviction was supported by some evidence consistent with due process.
2. Whether Richardson could rely on self-defense to invalidate the prison disciplinary conviction.
3. Whether the disciplinary hearing officer improperly relied on false or conflicting evidence.

Disposition

dismissed