Alexander Muniz v. Randy White, Acting Commissioner of the Kentucky Department of Corrections

CourtCourt of Appeals of Kentucky
DecidedFebruary 9, 2023
Docket2021 CA 000448
StatusUnknown

This text of Alexander Muniz v. Randy White, Acting Commissioner of the Kentucky Department of Corrections (Alexander Muniz v. Randy White, Acting Commissioner of the Kentucky Department of Corrections) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alexander Muniz v. Randy White, Acting Commissioner of the Kentucky Department of Corrections, (Ky. Ct. App. 2023).

Opinion

RENDERED: FEBRUARY 10, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2021-CA-0448-MR

ALEXANDER MUNIZ APPELLANT

APPEAL FROM LEE CIRCUIT COURT v. HONORABLE MICHAEL DEAN, JUDGE ACTION NO. 20-CI-00050

RANDY WHITE, ACTING COMMISSIONER OF THE KENTUCKY DEPARTMENT OF CORRECTIONS; DANIEL AKERS, WARDEN OF THE LEE ADJUSTMENT CENTER; AND JAMES STAMPER, ADJUSTMENT OFFICER OF THE LEE ADJUSTMENT CENTER APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, CETRULO, AND TAYLOR, JUDGES. TAYLOR, JUDGE: Alexander Muniz, pro se, brings this appeal from a February

23, 2021, order of the Lee Circuit Court dismissing Muniz’s declaration of rights

action. We affirm.

Muniz was an inmate at Lee Adjustment Center in Beattyville,

Kentucky, where he was serving a fifteen-year sentence of imprisonment for first-

degree manslaughter. On April 21, 2019, correction officers at Lee Adjustment

Center responded to an altercation in a dormitory involving multiple inmates.

Following a review of the security camera footage, it was determined that Muniz

was one of fourteen inmates involved in the altercation.

On May 17, 2019, a Disciplinary Report Write-Up and Investigation

(Disciplinary Write-Up) was prepared regarding Muniz’s involvement in the April

21, 2019, altercation. Then, on May 20, 2019, the Disciplinary Write-Up was

delivered to Muniz charging him with violating Kentucky Corrections Policies and

Procedures (CPP) 15.2 (II)(VII)(7), inciting to riot or rioting.1 Upon delivery, the

Disciplinary Write-Up was read to Muniz at 11:18 p.m. on May 20, 2019. Muniz

pleaded not guilty to the charged offense, waived the 24-hour notice requirement,

and requested a hearing.

1 Kentucky Corrections Policy and Procedures 15.2 (I) defines “riot” as “incites, instigates, organizes, plans, causes, aids, abets, assists or takes part in any disorder, disturbance, strike, or other organized disobedience to the rules of the institution.”

-2- The next morning, May 21, 2019, a prison disciplinary hearing was

conducted before the Adjustment Committee at 9:24 a.m. Pursuant to a

Disciplinary Report Hearing/Appeal (Disciplinary Report), Muniz was found

guilty of violating CPP 15.2 (II)(VII)(7), inciting to riot or rioting. Muniz was

sentenced to thirty-days’ segregation and forfeiture of 1,460 days of non-restorable

good-time credit. Muniz filed a timely appeal to Warden Daniel Akers. Warden

Akers reviewed the matter and concurred with the findings and penalties assessed

by the Adjustment Committee.

On May 15, 2020, Muniz filed a Petition for Declaration of Rights in

the Lee Circuit Court challenging the disciplinary proceeding. Therein, Muniz

generally asserted that the Department of Corrections violated his procedural due

process rights as protected by Sections 11 and 13 of the Kentucky Constitution, the

Due Process Clause of the Fourteenth Amendment to the United States

Constitution, and the CPP. The circuit court disagreed with Muniz and dismissed

his Petition for Declaration of Rights deciding that Muniz had “waived the 24 hour

notice requirement, and there was no due process violation.” February 23, 2021,

Order Dismissing at 3. This appeal follows.

Muniz contends the circuit court erred by dismissing his Petition for

Declaration of Rights without addressing the merits of his alleged due process

violations. Muniz asserts the circuit court summarily dismissed the Petition for

-3- Declaration of Rights solely upon the basis that Muniz had waived his right to

receive 24-hour notice of the prison disciplinary hearing as provided by CPP 15.2.

Muniz acknowledges that he waived the 24-hour notice but asserts that such

waiver did not extinguish his other due process rights related to the prison

disciplinary hearing.

It is generally agreed that due process rights applicable to a prison

disciplinary hearing can be waived by an inmate. See Yates v. Fletcher, 120

S.W.3d 728, 730 (Ky. App. 2003). To validly waive such a right, an inmate must

do so knowingly and intelligently. See Simms v. Commonwealth, 354 S.W.3d 141,

143 (Ky. App. 2011); see also 2 Michael B. Mushlin, Rights of Prisoners §10.2

(5th ed. 2020).

In this case, it is undisputed that Muniz signed the Disciplinary Write-

Up, and therein, Muniz agreed to waive the 24-hour notice requirement. It is

equally uncontroverted that Muniz did not waive any other due process rights in

the Disciplinary Write-Up. In fact, the Disciplinary Write-Up contained a

provision that allowed Muniz to waive his due process right to be present at the

disciplinary hearing; however, Muniz refused to waive the right. In light of the

clear facts, we conclude that Muniz only waived his right to 24-hour notice of the

disciplinary hearing and did not waive the other due process rights applicable to a

-4- Muniz next asserts that the adjustment committee violated his due

process rights by not providing him advance notice of the disciplinary hearing and

an opportunity to call witnesses and present evidence.

It is well established that prison disciplinary proceedings are not the

equivalent of a criminal prosecution, and inmates are not entitled to “the full

panoply of rights” that a criminal defendant possesses. Wolff v. McDonnell, 418

U.S. 539, 556 (1974). Rather, an inmate detained in lawful custody is only entitled

to minimal due process in a prison disciplinary proceeding where loss of good time

credit is at issue. Superintendent, Mass. Corr. Inst., Walpole v. Hill, 472 U.S. 445,

454 (1985) (citing Wolff v. McDonnell, 418 U.S. 539, 563-67 (1974); McMillen v.

Ky. Dep’t of Corr., 233 S.W.3d 203, 205 (Ky. App. 2007)). The minimal due

process rights afforded an inmate in a prison disciplinary proceeding include –

advance written notice of the disciplinary charges and an opportunity to call

witnesses and present evidence if consistent with institutional safety/correctional

goals. Walpole, 472 U.S. at 454 (citing Wolff, 418 U.S. at 563-67).

Regarding the right to receive advance notice, Muniz elected to waive

the right to receive 24-hour notice of the disciplinary proceeding. By waiving the

24-hour notice, Muniz, likewise, waived the advanced notice provided for in

Walpole. Walpole, 472 U.S. at 454; Yates, 120 S.W.3d at 730.

-5- Regarding an inmate’s right to have the opportunity to call witnesses

and present evidence, Muniz asserts that due to the short notice, he was essentially

deprived of the opportunity to do so. However, as Muniz waived the right to

advance notice of the hearing, he cannot complain of the lack of preparation time.

Additionally, Muniz failed to request the opportunity to present evidence or to call

witnesses at the hearing. As such, we do not believe Muniz’s minimal due process

right to present evidence or call witnesses as identified in Walpole was violated.

See Walpole, 472 U.S. at 454.

Muniz further maintains there was insufficient evidence to support the

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Related

Wolff v. McDonnell
418 U.S. 539 (Supreme Court, 1974)
Yates v. Fletcher
120 S.W.3d 728 (Court of Appeals of Kentucky, 2003)
McMillen v. Kentucky Department of Corrections
233 S.W.3d 203 (Court of Appeals of Kentucky, 2007)
Simms v. Commonwealth
354 S.W.3d 141 (Court of Appeals of Kentucky, 2011)
Ramirez v. Nietzel
424 S.W.3d 911 (Kentucky Supreme Court, 2014)

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Alexander Muniz v. Randy White, Acting Commissioner of the Kentucky Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alexander-muniz-v-randy-white-acting-commissioner-of-the-kentucky-kyctapp-2023.