Fernando Sanchez v. Warden, FCI Berlin

2023 DNH 051
CourtDistrict Court, D. New Hampshire
DecidedMay 3, 2023
Docket22-cv-231-SE
StatusPublished
Cited by1 cases

This text of 2023 DNH 051 (Fernando Sanchez v. Warden, FCI Berlin) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fernando Sanchez v. Warden, FCI Berlin, 2023 DNH 051 (D.N.H. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Fernando Sanchez

v. Case No. 22-cv-231-SE Opinion No. 2023 DNH 051 Warden, FCI Berlin

O R D E R

Fernando Sanchez, proceeding pro se, filed a petition for a

writ of habeas corpus pursuant to 28 U.S.C. § 2241, challenging

a disciplinary proceeding that resulted in his loss of 41 days

good conduct time (“GCT”). He contends that the disciplinary

hearing officer’s (“DHO”) decision that he committed the charged

prohibited act was not supported by any evidence. The warden

moves for summary judgment, arguing that at least some evidence

supports the DHO’s decision and, as such, Sanchez’s due process

rights were not violated.1 Doc. no. 9. Sanchez objects. Doc. no.

11. Because the record includes sufficient evidence to support

the charge against Sanchez, the court grants the warden’s motion

for summary judgment.2

1 Prior to filing his summary judgment motion, the warden moved for an extension of time to file his response to Sanchez’s § 2241 petition. Doc. no. 8. Sanchez did not object. The court grants that motion and considers the warden’s summary judgment motion herein.

2 The record suggests that Sanchez anticipated release while this motion was pending, but neither party has provided any such notice. Consequently, the court will render a decision on the merits. Standard of Review

Summary judgment is appropriate “if the movant shows that

there is no genuine dispute as to any material fact and the

movant is entitled to judgment as a matter of law.” Fed. R. Civ.

P. 56(a). A material fact is one that “carries with it the

potential to affect the outcome of the suit.” French v. Merrill,

15 F.4th 116, 123 (1st Cir. 2021) (quotation omitted). A

material fact is in genuine dispute if “a reasonable jury could

resolve the point in the favor of the non-moving party.” Id. The

court construes the record in the light most favorable to the

nonmoving party. Benson v. Wal-Mart Stores East, L.P., 14 F.4th

13, 17 (1st Cir. 2021). In considering a motion for summary

judgment, the court may review materials cited in the motion and

other materials in the record. Fed. R. Civ. P. 56(c)(1)(3).

Background

Sanchez’s petition challenges a disciplinary action against

him and sanction he received resulting from a September 5, 2021

incident report. During a routine search of Sanchez’s cell on

that date, officers found that the wooden pegs on which

prisoners hang their clothes in the cell were loose and that one

of the pegs had a sharpened end. The sharpened peg was 3.5

inches long and had a point on one end. The pegs were in a

common area of the cell where both Sanchez and his cellmate had

2 access to them. As a result, Sanchez was charged with violating

Prohibited Act Code 104, which proscribes the “[p]ossession,

manufacture, or introduction of a gun, firearm, weapon,

sharpened instrument, knife, dangerous chemical, explosive,

ammunition, or any instrument used as a weapon.” 28 C.F.R. §

541.3, table 1.

Sanchez denied the charge. The DHO held a hearing on

September 14, 2021, during which Sanchez explained that he had

been in the cell for “a month” and did not know the sharpened

peg was there.3 After the hearing, the DHO found that Sanchez had

violated Code 104. In making the finding, the DHO considered,

among other things, the officers’ statements, a photograph of

the sharpened peg, and Sanchez’s statements.

Sanchez appealed the DHO’s decision on the ground that the

evidence presented was insufficient to support a finding that he

had committed the charged violation. Sanchez argued that the

sharpened peg was never “used” as a weapon. His appeals were

unsuccessful.

Sanchez then filed the instant § 2241 petition, claiming

that the DHO’s decision violated his due process rights.

Although Sanchez’s petition does not address his appeal of the

3 Sanchez’s petition (doc. no. 1 at 9) and the DHO’s report (doc. no. 9-1 at 11) state that Sanchez had been in the cell for 23 days on the date of the incident.

3 DHO’s decision through the Bureau of Prisons’ (“BOP”) grievance

process, he states in his declaration in support of his

objection that he exhausted his administrative remedies. The

warden does not dispute that assertion.

Discussion

The court assumes without deciding that prisoners retain a

liberty interest in GCT and that 28 U.S.C. § 2241 remains a

proper vehicle by which to challenge disciplinary proceedings

resulting in the loss of GCT. See, e.g., Francis v. Maloney, 798

F.3d 33, 36-37 (1st Cir. 2015) (discussing how Pepper v. United

States, 562 U.S. 476, 501 n.14 (2011) may call into question

whether an prisoner can bring a habeas claim for relief

associated with lost GCT because Pepper states in dicta that GCT

“does not affect the length of a court-imposed sentence; rather,

it is an administrative reward” to incentivize compliance with

prison disciplinary regulations); cf. Wolff v. McDonnell, 418

U.S. 539, 557 (1974) (concluding prisoners have a liberty

interest in GCT because there is a statutory right to “a

shortened prison sentence through the accumulation of credits

for good behavior”).

The prisoner’s due process right in that context includes a

requirement that the decision revoking GCT is supported by at

least “a modicum of evidence” or, as is more commonly stated,

4 “some evidence.” See Superintendent, Massachusetts Corr. Inst.,

Walpole v. Hill, 472 U.S. 445, 454, 455-56 (1985). That standard

is minimal and is satisfied by even a meager amount of evidence.

See, e.g., DiGrazia v. Warden, FCI Berlin, No. 22-cv-441-JL,

2022 WL 17979911, at *3 (D.N.H. Dec. 5, 2022) (noting that the

“some evidence” standard is met if there is “‘any evidence in

the record’ in ‘support [of] the conclusion reached’” (quoting

Hill, 472 U.S. at 455-56)).

The warden seeks summary judgment on the ground that some

evidence supported the DHO’s finding that Sanchez possessed a

weapon, the sharpened peg. In support, he includes with his

motion the declaration of Cheryl Magnusson, a BOP legal

assistant, as well as certain documents, which include a copy of

Sanchez’s Sentence Monitoring Computation Data, his

Admission/Release History, the Incident Report, and the DHO

report.

In his objection, Sanchez argues that the record evidence

is insufficient to show that he violated Code 104. Specifically,

he argues that there was no evidence that he used the sharpened

wooden peg as a weapon and, viewed generously, that he was

unaware that the sharpened peg was in his cell.4 Sanchez filed a

4 Sanchez also appears to challenge the validity of the evidence the warden submitted in support of his summary judgment motion. See doc. no. 11 at 1-6. To the extent that he intended to lodge such a challenge, it is without merit.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Sanchez v. FCI Berlin, Warden
D. New Hampshire, 2023

Cite This Page — Counsel Stack

Bluebook (online)
2023 DNH 051, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fernando-sanchez-v-warden-fci-berlin-nhd-2023.