Shadavian Yard-Daniel v. Lloyd Arnold, Commissioner of IDOC

Summary

The United States District Court for the Southern District of Indiana denied Shadavian Yard-Daniel's petition for a writ of habeas corpus challenging an Indiana prison disciplinary conviction and sanctions. The court held that the proceedings satisfied due process, that the evidence supported the original and modified charges, and that the action should be dismissed with prejudice.

Holdings

1. A prisoner is not constitutionally entitled to a lay advocate at a disciplinary hearing absent illiteracy or unusual complexity, and Yard-Daniel showed neither circumstance.
2. Inmates do not have a constitutional right to assert self-defense as a defense in a prison disciplinary proceeding.
3. General allegations that a disciplinary hearing officer has a reputation for falsely convicting inmates do not overcome the presumption of honesty and integrity or establish unconstitutional bias.
4. The conduct report and video constituted some evidence supporting the disciplinary conviction, and Yard-Daniel's admission that he took a swipe at another inmate supplied sufficient evidence for the modified attempt-based charge.
5. Yard-Daniel's double-jeopardy claim was procedurally defaulted because he conceded that he failed to raise it on administrative appeal.
6. The court could consider the remaining claims on the merits rather than further analyze exhaustion.

Questions Presented

1. Whether Yard-Daniel was denied due process because his lay advocate did not speak during the disciplinary hearing.
2. Whether Yard-Daniel had a constitutional right to assert self-defense in the prison disciplinary proceeding.
3. Whether the disciplinary hearing officer was impermissibly biased and therefore denied Yard-Daniel an impartial decision-maker.
4. Whether the conduct report and video provided some evidence supporting the disciplinary conviction and the modified charge.
5. Whether Yard-Daniel's double-jeopardy claim was procedurally defaulted because he failed to raise it on administrative appeal.

Disposition

dismissed