Coley v. Hendrix

CourtDistrict Court, E.D. Arkansas
DecidedNovember 30, 2020
Docket2:20-cv-00015
StatusUnknown

This text of Coley v. Hendrix (Coley v. Hendrix) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Coley v. Hendrix, (E.D. Ark. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS DELTA DIVISION

ERIC COLEY PETITIONER Reg. #41404-424

v. No. 2:20-cv-00015-JTR

DEWAYNE HENDRIX, Warden, FCI-Forrest City Low RESPONDENT

MEMORANDUM AND ORDER1

I. Introduction Petitioner Eric Coley (“Coley”) filed this 28 U.S.C. § 2241 Petition for Writ of Habeas Corpus, challenging a prison disciplinary conviction he received while he was incarcerated at the Duluth Federal Prison Camp in Duluth, Minnesota.2 Doc. 1. Before addressing the merits of Coley’s habeas claims, it is important to understand the relevant facts giving rise to the challenged disciplinary conviction. On August 6, 2018, at 11:30 a.m., BOP Lieutenant Bergerson filed an Incident Report charging Coley with possession of a “Smartwatch” capable of cellular communication. Lt. Bergerson described the incident as follows: At approximately 1020 am, August 6, 2018, while reviewing a Smartwatch recovered on August 3, 2018, from the Chapel utility room. I turned the

1 The parties have consented to a United States Magistrate Judge conducting all proceedings in this civil action, including the entry of a final judgment. Doc. 10.

2 Coley filed this habeas action after being transferred to the Federal Correctional Institution in Forrest City, Arkansas. watch on to discover the current date and time as not being correct, the watch displayed a date of Saturday, 02/04/2017, and a time of 0455 pm. While reviewing the local call log, I discovered the following two phone numbers 331-725-1358 and 312-203-5579 as being called from this device. A search of 331-725-1358 in the Truview program revealed the number as an active number unique only to inmate Coley, Eric, Reg. No. 41014-424 account, specifically listed as his parent Mardell Coley. The 312-203-5579 phone number was not found within the Truview system.

Doc. 1 at 12. That afternoon, at 1:18 p.m., BOP Officer Henshaw delivered the Incident Report to Coley. Id. 3 On August 10, 2018, Coley attended an initial hearing conducted by the Unit Discipline Committee (“UDC”). At the hearing, Coley had “no comment.” Based on the severity of the charge, the UDC referred the matter to the Disciplinary Hearing Officer (“DHO”) to conduct a hearing. Id. On September 12, 2018, DHO Lee-Lo conducted a disciplinary hearing, during which Coley denied ever possessing the Smartwatch. He also called as a witness BOP Officer Montez, who apparently had confiscated a G-Shock watch from Coley on a different date. Officer Montez stated, “the G-Shock watch, I gave his watch back to him after inmate provided the receipt.” Id. Apparently, Coley believed Officer Montez’s testimony that Coley wore a G-Shock watch somehow aided his claim that he did not possess the Smartwatch. While both watches have a timekeeping function, only the Smartwatch can be used to place cell phone calls.

3 Coley attached all of the relevant disciplinary documents to his habeas Petition. Doc. 1 at 12-20. On September 20, 2018, DHO Lee-Lo entered his decision, concluding that Coley possessed the Smartwatch in violation of Code 108, “Possession,

Manufacture, Introduction, or Loss of a Hazardous Tool.” Doc. 1 at 13-15. Later that same day, DHO Lee-Lo delivered a copy of his decision to Coley. Id. at 15. In support of his decision, DHO Lee-Lo relied on the following evidence: (1)

Lt. Bergerson’s Incident Report; and (2) pictures of the black Smartwatch, USB cord, charger, and a Bluetooth earbud. Id. at 14. DHO Lee-Lo considered Coley’s testimony that he never possessed the Smartwatch, but gave greater weight to Lt. Bergerson’s account of the incident:

[T]he Smartwatch was found in the Chapel utility room on August 3, 2018. The date on the Smartwatch indicated February 4, 2017. This Smartwatch further indicated a call log with a phone number . . . an active number unique only to your [Carter’s] account, specifically listed as your parent Mardell Coley. Furthermore, DHO considered [Officer Martez’s] statement as irrelevant based on a different watch.

Id. As punishment, Coley received the following sanctions: (1) the loss of 41 days of good conduct time; and (2) the loss of 120 days of commissary, phone, and visitation privileges. Id. II. Discussion On January 23, 2020, Coley filed this § 2241 habeas action. In his Petition, he alleges that, in connection with this disciplinary conviction, his due process rights were violated in three ways: (1) The BOP failed to “promptly assign an incident report number generated by the prison’s SENTRY system.”

(2) Lt. Bergerson failed to “specify which rule factor was at issue and that the ‘tool’ in question was, in fact, a phone [sic] [Smartwatch].”

(3) The “familiar number” on the Smartwatch’s call log was insufficient evidence for DHO Lee-Lo to find that Coley possessed the Smartwatch.

Doc. 1 at 9. On March 18, 2020, Respondent filed a Response, arguing that Coley’s § 2241 Petition is without merit because his procedural due process rights were not violated and “some evidence” supports the disciplinary conviction. Doc. 5.4 On March 31, 2020, Coley filed a Motion asking the Court to stay his habeas action indefinitely because the BOP had restricted his access to the law library in response to the COVID-19 pandemic. Doc. 8. On April 1, 2020, the Court allowed Coley an additional 45 days to file his Reply. Doc. 9. Coley never filed a Reply nor requested additional time to do so. For the following reasons, the Court concludes that Coley’s habeas claims are without merit. Accordingly, this habeas action must be dismissed, with prejudice.

4 Because Respondent does not address whether Coley exhausted the BOP appeals process before bringing this action, that argument is now waived. See Lueth v. Beach, 498 F.3d 795, 797 n.3 (8th Cir. 2007) (exhaustion prerequisite for filing a § 2241 habeas petition is judicially created, not jurisdictional, and, thus, may be waived). A. Procedural Due Process and Wolff

A prisoner’s loss of good conduct time, as punishment for violating a prison rule, implicates liberty interests protected by the Due Process Clause. Espinoza v. Peterson, 283 F.3d 949, 951 (8th Cir. 2002). In Wolff v. McDonnell, 418 U.S. 539, 555-558 (1974), the Court held that, in a disciplinary hearing in which a prisoner

may lose good conduct time for violating a prison rule, procedural due process, at a minimum, requires that the prisoner: (1) receive written notice of the disciplinary charge at least 24 hours before the disciplinary hearing; (2) have an opportunity, when consistent with institutional safety and correctional goals, to call witnesses and

present documentary evidence in his defense; and (3) receive a written statement from an impartial decision maker identifying the evidence relied on to support the conviction and the reasons for the disciplinary action. Id. at 563-567.

First, Coley claims that, because the Incident Report giving rise to the disciplinary was not “numbered,” his due process rights were violated. The failure to assign a number to an Incident Report falls far short of the kind of meaningful procedural due process rights protected by Wolff. Accordingly, Coley’s claim that

his due process rights were violated, because the Incident Report was not “numbered,” is without merit.5

5 Coley also argues that the failure to assign a number to the Incident Report violated BOP policy. Doc. 1 at 3.

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Related

Wolff v. McDonnell
418 U.S. 539 (Supreme Court, 1974)
John L. Hrbek v. Crispus C. Nix
12 F.3d 777 (Eighth Circuit, 1994)
YSIDRO ESPINOZA, — v. T.C. PETERSON, —
283 F.3d 949 (Eighth Circuit, 2002)
Hartsfield v. Nichols
511 F.3d 826 (Eighth Circuit, 2008)
Lueth v. Beach
498 F.3d 795 (Eighth Circuit, 2007)

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Coley v. Hendrix, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coley-v-hendrix-ared-2020.