0:25-cv-02302•Williams v. Rardin
Gesamter Gesetzestext
UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Joseph Williams, Case No. 25-cv-2302 (JRT/DTS) Petitioner, REPORT AND RECOMMENDATION v. Jared Rardin, Warden, Respondent. INTRODUCTION Petitioner Joseph Williams, currently incarcerated at the Federal Medical Center in Rochester, Minnesota, seeks a Writ of Habeas Corpus reinstating 41 days of good conduct time he lost following a disciplinary hearing. At the hearing, a Disciplinary Hearing Officer (DHO) concluded that Williams had violated prison rules by possessing a sharpened aluminum can lid. Williams contends that he was unconstitutionally deprived of the good conduct time because the DHO lacked sufficient evidence to support their conclusion, and the hearing violated BOP policy. For the reasons set forth below, the Court recommends his petition be denied. FINDINGS OF FACT In January 2025, Corrections Officer Burkholder conducted a cell search and found a sharpened aluminum can lid located under the mattress of Williams’ bunk. Fitcher Decl. ¶ 9, Ex. D at 1, Dkt. No. 12. Four inmates, including Williams, were assigned to the cell. Id. Williams was charged with possession of a hazardous tool. Id. ¶ 9, Ex. C. He received a copy of the incident report and was advised of his rights during the disciplinary process. Id. ¶ 14, Ex. D at 3. Williams claimed that his cellmate, J. Mc., placed the can lid under CASE 0:25-cv-02302-JRT-DTS Doc. 14 Filed 11/03/25 Page 1 of 7
2 his mattress. Id. The incident was referred to the Unit Disciplinary Committee (UDC) who conducted an initial review of the charge. Id. At the UDC hearing, Williams again denied ownership of the can lid, reiterating that it belonged to J. Mc. Id. ¶ 15, Ex. F at 2. Lieutenants interviewed J. Mc. who confirmed that the can lid was his and that he had left it under Williams’ mattress prior to his removal to the Special Housing Unit three weeks earlier. Id. Ex. F at 2-3. Upon consideration of the evidence, the UDC recommended that the incident report for Williams be expunged. Id. Ex. F at 2. Because of the nature of the charge, the UDC referred the report to a DHO. Id. ¶ 15, Ex. F at 2. Williams received and signed a form explaining his rights during the DHO hearing. Id. Ex. G. The hearing in front of the DHO occurred in March 2025. Id. ¶ 16. Williams again denied ownership of the can lid stating I work everyday. The only time I'm in the unit is during count time. I was in there only two months. They threw me in there with a bunch of junkies. I wouldn't risk everything for something to cut my food up. That lid is not mine. Id. ¶ 17, Ex. I at 1. The DHO also obtained a written statement from J. Mc. confirming that it “was [his] can lid” and that he hid it under Williams’ mattress because “that’s [his] cousin.” Id. ¶ 17, Ex. I at 2. Considering the testimony at the hearing and the documentary evidence, the DHO determined that Williams possessed the can lid. Id. ¶ 18, Ex. I at 3. The DHO did not deny the possibility that J. Mc. placed the can lid under Williams’ mattress. Id. ¶ 19, Ex. I at 3- 4. Nonetheless, they concluded that it was Williams’ “responsibility to ensure [his] area is free of contraband,” particularly since J. Mc. had not been in the cell for three weeks. Id. ¶ 19, Ex. I at 4. Further, the DHO found J. Mc.’s statement unpersuasive, reasoning that CASE 0:25-cv-02302-JRT-DTS Doc. 14 Filed 11/03/25 Page 2 of 7
3 “[i]nmates lie to staff all the time, in an attempt to help other inmates avoid consequences.” Id. As a sanction, the DHO revoked 41 days of Williams’ good conduct time, imposed 23 days of disciplinary segregation, issued a $100 fine, and suspended commissary and email privileges for three months. Id. ¶ 18, Ex. I at 4. Williams received a copy of the DHO Report on March 13, 2025. Id. ¶ 16, Ex. I at 5. The written report advised him of his right to appeal the decision using the BOP administrative remedies process. Id. On April 8, 2025, Williams appealed the sanctions to the BOP Regional Director’s Office.1 Bush Decl. ¶ 18, Ex. B at 2. On May 14, 2025, the Regional Director denied the appeal finding that the DHO had “sufficiently addressed the evidence used to make a finding of guilt.” Id. Ex. B at 1. The written report advised Williams of his right to appeal the decision to the BOP Office of General Counsel within 30 days. Id. Williams did not do so. Id. ¶ 19. Williams filed this habeas petition on June 2, 2025. Pet., Dkt. No. 1. He alleges the DHO’s findings were not supported by the evidence and that the hearing violated BOP policy. Amend. Pet. 2-3, Dkt. No. 9. Respondent opposes, contending that Williams failed to exhaust his administrative remedies and, even if he had, his claims lack merit. Resp. Mem. 1, Dkt. No. 10. CONCLUSIONS OF LAW I. Exhaustion of Administrative Remedies A federal prisoner generally must exhaust BOP administrative remedies before seeking habeas relief under 28 U.S.C. § 2241. However, the exhaustion prerequisite is 1 Williams initially filed the appeal on March 27, 2025, but it was rejected for being illegible. Bush Decl. ¶ 15, Ex. A at 2. CASE 0:25-cv-02302-JRT-DTS Doc. 14 Filed 11/03/25 Page 3 of 7
4 judicially created, and courts may hear unexhausted grievances where proceeding with the remedies process would be futile. E.g., Raymond v. Bd. of Regents of the Univ. of Minn., 847 F.3d 585, 591 (8th Cir. 2017). Respondent argues that Williams failed to exhaust his administrative remedies because he did not file a final appeal with the Office of General Counsel. Resp. Mem. 5- 10. This Court agrees. The BOP Administrative Remedy Process detailed in 28 C.F.R. § 542.10–19 includes four essential steps. Bush Decl. ¶ 5. First, an inmate must seek informal resolution with prison staff using a Requests for Informal Resolution Form (BP- 8). Bush Decl. ¶ 6. Second, if no informal resolution is met, he may then file a formal Request for Administrative Remedy (BP-9) with the Warden. Id. Third, if the inmate is dissatisfied with the Warden’s response, he can appeal to the Regional Director by filing a Regional Office Administrative Remedy Appeal (BP-10). Id. Finally, if dissatisfied with the Regional Director's response, the inmate may appeal to the Director, National Inmate Appeals, in the Office of the General Counsel in Washington, D.C. by filing a Central Office Administrative Remedy Appeal (BP-11). Id. This is the final administrative appeal. Id. ¶ 8. When an inmate is appealing a DHO’s decision, they may bypass the first two steps and appeal straight to the Regional Director’s Office. Id. ¶ 7. Here, Williams filed a BP-10 appeal to the Regional Director’s Office but failed to file a BP-11 appeal to the Office of General Counsel, despite being advised he had 30 days to do so. Id. ¶¶ 18-19. Because the deadline to file a BP-11 has passed, he can no longer complete the administrative process. Therefore, this Court considers the merits of Williams’ claims on the basis that requiring further exhaustion would be futile. See Lueth CASE 0:25-cv-02302-JRT-DTS Doc. 14 Filed 11/03/25 Page 4 of 7
5 v. Beach, 498 F.3d 795, 797 n.3 (8th Cir. 2007) (holding the Court has jurisdiction to address merits notwithstanding the failure to exhaust administrative remedies). II. Due Process Violation Williams argues his due process rights were violated because (1) the DHO improperly disregarded J. Mc.’s statement and the UDC’s recommendation that the incident report be expunged; and (2) the DHO violated BOP policy by holding a hearing without a referral from the UDC. Amend. Pet. 2-3. A challenge to the revocation of good conduct time is properly raised in a habeas petition. Prieser v. Rodriguez, 411 U.S. 475, 487 (1973). However, “federal courts are not part of the appellate process for prison disciplinary proceedings.” Toombs v. Hicks, 773 F.2d 995, 997 (8th Cir. 1985). Deprivation of good conduct time, which may shorten a term of imprisonment, implicates a liberty interest that is protected by the Due Process Clause. See Wolff v. McDonnell, 418 U.S. 539, 557-58 (1974). Although not entitled to “the full panoply of rights due a defendant” in a criminal prosecution, id. at 555, an inmate subject to prison disciplinary proceedings must receive (1) advance written notice of the disciplinary charges; (2) an opportunity, consistent with institutional safety and correctional goals, to call witnesses and present documentary evidence in his defense; and (3) a written statement by the factfinder of the evidence relied on and the reasons for the disciplinary action. Superintendent, Mass. Corr. Inst., Walpole v. Hill, 472 U.S. 445, 454 (1985) (citing Wolff, 418 U.S. at 563-67). In addition, the disciplinary findings must be supported by “some evidence in the record.” Id. This standard is met if “there was some evidence from which the conclusion CASE 0:25-cv-02302-JRT-DTS Doc. 14 Filed 11/03/25 Page 5 of 7
6 of the administrative tribunal could be deduced ....” Id. at 455-56. This does not require the court to weigh the evidence or assess witness credibility. Id. “Even when there is substantial evidence to the contrary, [a hearing officer] may find a guard's report to be credible and therefore take disciplinary action.” Hrbek v. Nix, 12 F.3d 777, 781 (8th Cir. 1993). Here, the DHO based their determination on “some evidence.” The can lid was found under Williams’ mattress and even if J. Mc. had placed it there, J. Mc. had not accessed the cell in three weeks. Based on those facts, the DHO made a rational inference that Williams possessed the can lid. That a different inference or conclusion could be drawn from the evidence is not for this Court to decide. Hrbek, 12 F.3d at 781. Moreover, Williams’ arguments that the DHO improperly disregarded J. Mc.’s statement and the UDC’s recommendation are unavailing. Amend. Pet. 2-3. As stated above, this Court does not revisit the DHO’s credibility determinations or reweigh the evidence on habeas review. Hill, 472 U.S. at 455-56. Additionally, Williams’ assertion that the DHO hearing violated BOP policy is without merit. 28 C.F.R. § 541.8 provides that a DHO “will only conduct a hearing on the incident report if referred by the UDC.” Here, the hearing aligned with BOP policy because the UDC’s report referred the incident to a DHO and Williams signed a form acknowledging such. See Fitcher Decl. Exs. F at 2, G. Because the DHO based their determination on “some evidence” and the hearing was conducted in accordance with BOP policy; Williams’ due process rights were satisfied, and habeas relief is unwarranted. CASE 0:25-cv-02302-JRT-DTS Doc. 14 Filed 11/03/25 Page 6 of 7
7 RECOMMENDATION For the reasons set forth above, the Court RECOMMENDS THAT: 1. Petitioner Joseph Williams’ Amended Habeas Petition (Dkt. No. 9) be DENIED; and 2. This matter be DISMISSED WITH PREJUDICE Dated: November 3, 2025 __s/ David T. Schultz______ DAVID T. SCHULTZ United States Magistrate Judge NOTICE Filing Objections: This Report and Recommendation is not an order or judgment of the District Court. It is not appealable directly to the Eighth Circuit Court of Appeals. Under Local Rule 72.2(b)(1), “a party may file and serve specific written objections to a magistrate judge’s proposed finding and recommendations within 14 days after being served a copy” of the Report and Recommendation. A party may respond to those objections within 14 days after being served a copy of the objections. LR 72.2(b)(2). All objections and responses must comply with the word or line limits set for in LR 72.2(c). CASE 0:25-cv-02302-JRT-DTS Doc. 14 Filed 11/03/25 Page 7 of 7
Was bedeutet dieser Text für Ihre Situation?
Kostenlose und unverbindliche Beratung
Schildern Sie uns Ihre Situation. Unser Team meldet sich per E-Mail bei Ihnen für Ihre Beratung.
Setzen Sie Ihre Recherche in ChatGPT oder Claude fort
Verbinden Sie Omnilex, um den Rechtskorpus über Ihren KI-Assistenten zu durchsuchen.