Shadavian Yard-Daniel v. Pretorious, Warden

Summary

The United States District Court for the Southern District of Indiana denied Shadavian Yard-Daniel's habeas petition challenging an Indiana prison disciplinary conviction for possessing intoxicants. The court held that alleged IDOC policy violations, denial of a witness or chemical testing, alleged hearing-officer bias, and insufficient-evidence claims did not establish a due-process violation, and it dismissed the action with prejudice.

Holdings

1. Alleged violations of state prison policies do not provide a basis for federal habeas relief.
2. Due process was not violated because Yard-Daniel was given an opportunity to obtain the requested witness information, and he was not entitled to additional chemical testing where other evidence was available.
3. The hearing officer was not shown to be impermissibly biased.
4. The disciplinary conviction satisfied the constitutional some-evidence standard.

Questions Presented

1. Whether alleged violations of Indiana Department of Correction policies concerning the timing and content of the disciplinary proceeding stated a cognizable federal habeas claim.
2. Whether Yard-Daniel was denied due process when he was allegedly denied a material witness and testing of the confiscated paper.
3. Whether the disciplinary hearing officer was impermissibly biased.
4. Whether the disciplinary conviction was supported by some evidence despite the absence of chemical testing.

Disposition

dismissed