Martin Ray Hiatt v. State of Iowa

IN THE COURT OF APPEALS OF IOWA
_______________

No. 24-1129
Filed April 1, 2026
_______________

Martin Ray Hiatt,
Applicant–Appellant,
v.
State of Iowa,
Respondent–Appellee.
_______________

Appeal from the Iowa District Court for Polk County,
The Honorable Jeanie Vaudt, Judge.
_______________

AFFIRMED
_______________

Martin Ray Hiatt, Fort Dodge, self-represented appellant.

Brenna Bird, Attorney General, and Patrick C. Valencia, Deputy Solicitor
General, attorneys for appellee.
_______________

Considered without oral argument
by Greer, P.J., and Schumacher and Ahlers, JJ.
Opinion by Greer, P.J.

1
GREER, Presiding Judge.

In his postconviction-relief (PCR) application related to a prison
disciplinary matter, Martin Hiatt asserted that his grievance with prison
officials impacted his due process rights.1 Hiatt requests that the court
“define the parameters excluding administrative rules and policies that
operate to by-pass the Wolff2 mandatory due process components.” More
simply, he contends his property and liberty rights were violated by the
discipline he received when he was reclassified to another, more secure unit
without a proper disciplinary process. The State argues that Hiatt’s
disagreement over his inmate security classification “implicates neither a
cognizable property nor liberty interest” requiring summary dismissal of the
PCR application.3 We affirm the dismissal of the PCR petition because Hiatt
failed to establish a right to relief from his reclassification.

I. Background Facts and Proceedings.

On July 6, 2022, the Fort Dodge correctional facility was on “lock-
down.” Only those prisoners who had worked that day were allowed

1
Hiatt was serving a twenty-five-year sentence for three counts of sexual abuse in
the second degree. In his PCR application, he also requested an award of $25,000 for his
pain and suffering.
2
Wolff v. McDonnell, 418 U.S. 539, 557 (1974) (discussing prison disciplinary
procedures involving denial of good-time credit, noting “the Due Process Clause does not
require a hearing ‘in every conceivable case of government impairment of private
interest’” (citation omitted)).
3
In Hiatt’s reply brief he asserts that the State filed its brief untimely. Prior to
filing his reply brief, Hiatt filed a motion to strike the State’s brief for untimeliness. As
the supreme court said in response to Hiatt’s motion to strike: “Briefing deadlines are not
jurisdictional, and the court may extend or shorten them. Iowa R. App. P. 6.1003(2).”
The supreme court granted the State an extension to file its brief, and the State timely filed
within that deadline.

2
showers. Hiatt, who had not worked, requested a shower, which he had not
had for “roughly 56 hours.” According to the note describing the incident,
Hiatt showered but failed to mention the “whole truth” to staff that he had
not worked that day. In the “generic note”4 outlining his correctional
violation, it was asserted that Hiatt “was seen for a level review today for
manipulating staff,” and Hiatt “took no responsibility for his actions.” His
consequence was to relocate to a more restrictive area after a panel of three
prison officials reviewed the incident. On August 9, Hiatt filed a grievance,
which the grievance officer noted was “non-grievable.” Hiatt appealed.
After reviewing the grievance appeal, the Iowa Department of Corrections
(IDOC) executive officer determined that “this is a non[]-grievable matter in
the fact that this is a formal classification/treatment appeal process,” and as
such, needed to be filed with the grievance officer within thirty days of the
alleged incident, which time had passed. The grievance appeal was denied.

After Hiatt filed his pro se PCR application under Iowa Code
section 822.2(1)(e) (2022),5 the State moved for summary judgment. Hiatt
argued his reclassification to a more secure area in the prison and the fact he

4
According to Hiatt, the “Generic Note is for documentary use alone, not to
implement disciplinary actions against inmates.”
5 Iowa Code section 822.2(1)(e) provides that:

1. Any person who has been convicted of, or sentenced for, a public
offense and who claims any of the following may institute, without paying
a filing fee, a proceeding under this chapter to secure relief:

....

e. The person’s sentence has expired, or probation, parole, or
conditional release has been unlawfully revoked, or the person is otherwise
unlawfully held in custody or other restraint.

3
was deprived of his job and property because of the reclassification, was done
without due process. Hiatt argued that:
it is DOC policy that generic notes are for documentary only. They are not
used for disciplinary. That is their own policy. And policy also states to
lose a level or have a job removal, you have to be found guilty by an ALJ
and a major report. None of this ever happened for me. . . . To have a
classification, you need a treatment director, a deputy warden, or the
warden has to be present to be considered a classification team.

In response, the State asserted, “You can only file such an action [under
section 822.2(1)(e)], . . . if you have, as a result of the actions of the staff in
the prison, have, one, lost earned time, or, two, been substantially deprived
of a liberty or property interest.” It asserted the reclassification did not result
in a deprivation of a cognizable liberty or property interest. The PCR court
denied the PCR application, but as both Hiatt and the State agree, did so by
applying incorrect facts.6 Hiatt appeals.

II. Standard of Review.

Our review of summary judgment rulings are “for correction of errors
at law.” Nelson v. Lindaman, 867 N.W.2d 1, 6 (Iowa 2015). Generally our
review of PCR proceedings is for correction of errors at law. Manning v. State,
654 N.W.2d 555, 558–59 (Iowa 2002). “Constitutional issues, however, are
reviewed de novo.” Smith v. State, ___N.W.3d ___, ___, 2026 WL 545962,
at *2 (Iowa 2026).

III. Error Preservation.

The State asserts that Hiatt failed to preserve error on his arguments
that the IDOC did not follow the Wolff due process parameters to allow him

6
The district court mixed up the prison facilities in the ruling, but we do not find
those errors impacted the legal implications of the issues presented here.

4
a disciplinary hearing and that he has a federal constitutional challenge.
Without deciding this issue, we choose to address Hiatt’s appellate
arguments.

IV. Analysis.

After Hiatt filed a PCR application in March 2024, seeking a
classification decision related to his correctional facility status, the State
moved for summary judgment to dismiss the claim. The State asserted that
Hiatt failed to state a claim upon which relief can be granted as Hiatt’s
violation of restricted movement status and the change in classification to a
different area of the prison as a punishment was not a violation of any
recognized liberty or property interest. The State produced the IDOC
policies related to reclassification. IDOC policy IS-CL-02 IV (C)(2)(h) states:
“Classification decisions are not grievable. Each institution shall have
written procedures for incarcerated individuals to appeal the classification
decisions. Appeals beyond the institutional level are not allowed.”

Under Iowa Code section 822.6(3), a PCR court may grant a summary
judgment motion “when it appears from the pleadings, depositions, answers
to interrogatories, and admissions and agreements of fact, together with any
affidavits submitted, that there is no genuine issue of material fact and the
moving party is entitled to judgment as a matter of law.” Smith, ___ N.W.3d
at ___, 2026 WL 545962, at *3. Under that guidance, the district court
determined that Hiatt failed to show that he suffered a substantial deprivation
of his liberty or property interest, citing cases that show no liberty interest
was implicated in an assignment to any particular prison. Thus, the district
court determined that PCR was unavailable to Hiatt under the undisputed
facts as presented. The court dismissed the PCR application.

5
We look to the two situations where a district court may review prison
disciplinary proceedings through postconviction relief. Tabor v. State, 519
N.W.2d 378, 380 (Iowa 1994). “The first situation exists where the
discipline results in a reduction of an inmate’s good and honor time.” Wycoff
v. Iowa Dist. Ct., 580 N.W.2d 786, 787 (Iowa 1998). That is not the situation
that we have here. Moving to the second situation, it applies “where the
prison discipline results in a substantial deprivation of the inmate’s liberty or
property interests.” Id.; Davis v. State, 345 N.W.2d 97, 99 (Iowa 1984).
From our review of the PCR application and record, this second situation
forms the basis of Hiatt’s PCR challenge.

Setting aside the question of whether Hiatt timely appealed his
grievance below or whether procedures related to his grievance were
followed, we look to whether the State is correct that the reclassification and
resulting changes did not amount to a cognizable property or liberty interest.
From that lens, we consider Hiatt’s contention that his classification change
is a greater degree of confinement than previously enjoyed and thus does
constitute a substantial deprivation of a liberty interest. See Davis, 345
N.W.2d at 98–99. But, “[w]e have previously suggested transfers do not
involve atypical or significant hardships on inmates in relation to the ordinary
incidents of prison life.” See Wycoff, 580 N.W.2d at 787–88.

We take some guidance from cases addressing similar arguments as
those Hiatt advances. In Smith v. McKinney, 954 F.3d 1075 (8th Cir. 2020),
the court granted summary judgment dismissing Smith’s due process claim
that he had a liberty interest in avoiding restrictive prison conditions. Id. at
1079–84. Smith was transferred to a higher security prison after a
disciplinary action, that later was expunged from his record as he was found
not to have violated the rules. Id. at 1077–78. In his PCR claim, Smith argued

6
“the decision to commit [him] to disciplinary detention and transfer him in
the first instance was based on a disciplinary allegation and report that has
since been expunged because a court held that there was not even ‘some
evidence’ that [he] violated the prison rules.” Id. at 1079. In dismissing the
PCR claim, the court reasoned that “the Supreme Court has held that the
Constitution itself does not give rise to a liberty interest in avoiding transfer
to more adverse conditions of confinement.” Id. (cleaned up). Likewise, the
court noted that prison administrators can transfer prisoners “for whatever
reason or for no reason at all.” Id. at 1080 (citation omitted).

Here, Hiatt could not show that his transfer to a higher security unit
imposed any departure from the “ordinary incidents of prison life,” which is
the starting point for a due process challenge related to deprivation of liberty.
Sandin v. Conner, 515 U.S. 472, 484, 487 (1995) (denying the due process
claim after prison officials refused the prisoner’s request to call witnesses at
a disciplinary hearing where the issue was his segregation for misconduct);
see also Wilkinson v. Austin, 545 U.S. 209, 223–24 (2005) (describing the
characteristics of confinement that imposes “atypical and significant
hardship” on an inmate). The focus of the liberty inquiry does not rest on
the language of a particular regulation, but on the nature of the deprivation,
as the former “encourage[s] prisoners to comb regulations in search of
mandatory language on which to base entitlements to various state-conferred
privileges.” Sandin, 515 U.S. at 473; see also Sanford v. Manternach, 601
N.W.2d 360, 365 (Iowa 1999) (discussing the Supreme Court’s shift in focus
to the nature of deprivation).

As for Hiatt’s claim that he suffered a deprivation of his
constitutionally protected property interest, his argument fails. Hiatt does
not have a property interest in any specific prison job nor does he have a

7
constitutional right to access any mattress topper within the prison walls.
Our legislature had allowed for inmate work programs “in industries
established and maintained in connection with the institutions by the
director.” See Iowa Code § 904.703(1) (noting the work program would be
provided “for trustworthy inmates of state correctional institutions”). But
Hiatt does not cite—nor could we find—any support for the argument that
instituting work programs translates into a constitutionally protected
property right. “The primary purpose of prison employment is inculcation
or the reactivation of attitudes, skills, and habit patterns which will be
conducive to prisoner rehabilitation.” Frederick v. Men’s Reformatory, 203
N.W.2d 797, 798 (Iowa 1973) (cleaned up). And prisoners do not even have a
protected property right to prison wages. State v. Love, 589 N.W.2d 49, 51
(Iowa 1998) (“The allowance is a gratuitous payment and is not a wage arising
out of an employment relationship.” (emphasis in original) (cleaned up)); see
also Iowa Code § 904.701(2) (same).

Like the prison job, Hiatt has not convinced us that his use of a
mattress topper, which was not allowed after his transfer, is a cognizable
constitutional right to property. Hatten v. White, 275 F.3d 1208, 1210 (10th
Cir. 2002) (finding there is a difference between owning property and
possessing property in prison and where the prisoner “was allowed to send
the property he could not possess in prison to a place of his choosing,” there
was no deprivation of property).

After determining that Hiatt had “manipulated” prison staff into
allowing him a shower, prison officials determined that Hiatt posed a risk in
the lower-security unit in which he was placed because residing there carried
with it “a lot of responsibility.” Although the change in status meant that
Hiatt could not continue working at his previous job as a protocol worker and

8
the rules at the higher-security unit meant he could not use a mattress topper,
Hiatt did not identify any other restrictions or changes impacting him. In
sum, we cannot find Hiatt has shown a property or liberty interest of
constitutional dimension.

Finally, because a liberty interest was not identified by Hiatt, as was
required to access the Wolff hearing process, his challenge to the process fails
as well. See Meachum v. Fano, 427 U.S. 215, 225–26 (1976) (noting Wolff
procedural protections were implicated when an inmate was deprived of
good-time credits and declining to enter the day-to-day discretionary
function of state prisons in decisions involving what prison to transfer a
prisoner); see also Sandin, 515 U.S. at 477–82.

Thus, because the gist of the challenge relates to a reclassification of
Hiatt’s prison status to a higher security unit, where he could not work in his
same job and had to send his mattress topper back home, it is undisputed that
neither a property nor a liberty interest of Hiatt’s was implicated. As a matter
of law, as Hiatt failed to show entitlement to any PCR remedy, the district
court correctly applied the law and granted the motion for summary
judgment dismissing Hiatt’s PCR claim.

AFFIRMED.

9