Shawn McMullin v. Frank Vanihel, WVCF Warden

Summary

The United States District Court for the Southern District of Indiana denied Shawn McMullin's petition for a writ of habeas corpus under 28 U.S.C. § 2254. The court held that his mental-health arguments did not establish a due-process violation and that some evidence supported the disciplinary convictions and restitution sanction arising from four prison disciplinary proceedings.

Holdings

1. Prisoners with mental illness are not constitutionally entitled to heightened procedural protections beyond those required by Wolff v. McDonnell, and the prison was not required to conduct a formal mental-competency evaluation before the disciplinary hearings on the facts presented.
2. A violation of prison policies, regulations, or guidelines does not support relief under § 2254 because those policies do not constitute federal law or the Constitution and generally do not create enforceable inmate rights.
3. The conviction for battery on staff and the related restitution order satisfied the constitutional some-evidence standard.
4. A disciplinary proceeding that does not affect the fact or duration of custody, including one imposing only a loss of commissary and telephone privileges, does not state a viable basis for habeas relief.

Questions Presented

1. Whether McMullin's alleged mental-health impairments required heightened procedural protections or a formal competency evaluation in the prison disciplinary proceedings.
2. Whether alleged violations of Indiana Department of Correction policy provided a basis for federal habeas relief.
3. Whether the disciplinary conviction for battery on staff and the related restitution order were supported by some evidence.
4. Whether the disciplinary case imposing only a loss of commissary and telephone privileges was cognizable in habeas because it did not affect the fact or duration of custody.

Disposition

dismissed