HUNTER v. WARDEN

CourtDistrict Court, S.D. Indiana
DecidedDecember 19, 2024
Docket1:24-cv-01069
StatusUnknown

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

Bluebook
HUNTER v. WARDEN, (S.D. Ind. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

EUGENE HUNTER, ) ) Petitioner, ) ) v. ) 1:24-cv-01069-SEB-KMB ) WARDEN, ) ) Respondent. )

ORDER DENYING PETITION FOR WRIT OF HABEAS CORPUS AND DIRECTING ENTRY OF FINAL JUDGMENT

Eugene Hunter has filed a Petition for a Writ of Habeas Corpus under 28 U.S.C. § 2254. [Filing No. 2.] He challenges a prison disciplinary proceeding in which he was found guilty of Offense B-204, sexual contact, and sanctioned with a 30-day loss of good-time credits, along with other non-custodial sanctions not relevant to this proceeding. [Filing No. 10-6.] For the reasons explained below, the disciplinary proceeding did not violate Mr. Hunter's due process rights and his habeas petition is DENIED. I. LEGAL BACKGROUND

Prisoners in Indiana custody may not be deprived of good-time credits or of credit-earning class without due process. Ellison v. Zatecky, 820 F.3d 271, 274 (7th Cir. 2016); Scruggs v. Jordan, 485 F.3d 934, 939 (7th Cir. 2007); see also Rhoiney v. Neal, 723 F. App'x 347, 348 (7th Cir. 2018). The due process requirement is satisfied with: 1) the issuance of at least 24 hours advance written notice of the charge; 2) a limited opportunity to call witnesses and present evidence to an impartial decision-maker; 3) a written statement articulating the reasons for the disciplinary action and the evidence justifying it; and 4) "some evidence in the record" to support the finding of guilt. Superintendent, Mass. Corr. Inst. v. Hill, 472 U.S. 445, 454 (1985); see also Wolff v. McDonnell, 418 U.S. 539, 563-67 (1974). II. FACTUAL BACKGROUND

On July 17, 2023, Investigator H. Kern wrote a Conduct Report in which she stated: On 7/17/2023 at approximately 1:04PM I Investigator H. Kern was supervising visits in the visiting room. Upon supervising visits in the visiting room I was informed that Offender Eugene Hunter #179720 hand made physical contact with the visitor he was visiting at the end of his visit on her buttocks. Per Policy 02-04- 101 Sexual Contact is defined as contact between persons that includes touching of the intimate parts of one person to any part of another person, whether clothed or unclothed; clutching, exposing, fondling or touching one's intimate parts for the sexual arousal of themselves or others, whether clothed or unclothed while observable by others. Intimate Parts include: Breasts, penis, buttocks, scrotum, or vaginal area or any other part of the body that may result in sexual arousal or gratification for either party. Offenders are only allowed to shake hands and/or embrace at end of the visit, kissing and inappropriate touching is strictly prohibited.

[Filing No. 10-1.] Mr. Hunter was notified of the charge on July 19, 2023 when he received a copy of the Conduct Report and the Screening Report. [Filing No. 10-1; Filing No. 10-2.] He pled not guilty to the offense and requested a lay advocate, but did not request any witnesses or physical evidence when he completed the Screening Report. [Filing No. 10-2.] The same day, however, Mr. Hunter completed a Request for Interview Form in which he stated: I was screened by you. I want to request the video footage of this alleged incident/act and or any physical evidence in regard to case no. CIC-23-07-001069. I am in need of this evidence so I can prepare my defense for my upcoming DHB Hearing. Thank you. Will you send me a document writing down the requested video footage evidence and physical evidence of incident please stamp filed. Thank you.

[Filing No. 10-5.] 2 On August 17, 2023, Sgt. J. Pardue completed a Video Evidence Review Form in which he stated: "I Sgt. J. Pardue reviewed video footage for CIC 23-07-001069. During the video review offender Hunter #179720 can be seen grabbing his visitor[']s buttocks two separate times at the end of his visit." [Filing No. 10-7.]

After two postponements of the hearing due to "case load," [Filing No. 10-4], a hearing was held on August 29, 2023, [Filing No. 10-6]. Mr. Hunter appeared at the hearing, pled not guilty, and provided the following statement: I've never had a visit here before. I didn't know that I couldn't do that. I know I am not allowed to kiss because that was told to me, so I didn't kiss her. If I had known it was a rule it would have been different. I have a lot I am going through right now. I have DCS stuff I am going through right now. I really think this should be a C conduct.

[Filing No. 10-6 at 1.] The disciplinary hearing officer ("DHO") considered photos of the visitation room, the Conduct Report, Mr. Hunter's statement, and video evidence. [Filing No. 10- 6.] The DHO concluded that Mr. Hunter was guilty of Offense B-204, Sexual Contact, writing: "I relied on video that shows Hunter grabbing his visitor['s] buttocks two times. Policy was reviewed and this does constitute a B204 Sexual Contact." [Filing No. 10-6.] Mr. Hunter was sanctioned with a 30-day loss of good-time credits, along with other non-custodial sanctions not relevant to this proceeding. [Filing No. 10-6.] Mr. Hunter appealed to the Facility Head and the IDOC Final Reviewing Authority, and both appeals were denied. [Filing No. 10-8; Filing No. 10-9.] He then brought this Petition for a Writ of Habeas Corpus pursuant to 28 U.S.C. § 2254. [Filing No. 2.]

3 III. ANALYSIS

Mr. Hunter raises four grounds in his Petition: (1) that the DHO was not impartial; (2) that his request for the name of the staff member who reported the incident to Investigator Kern and for the description of the incident given to Investigator Kern were improperly denied; (3) that the Conduct Report does not contain sufficient detail to provide him with adequate notice of the charges; and (4) that the evidence was not sufficient to support a finding of guilt. [Filing No. 2 at 2-5.] The Respondent argues that Mr. Hunter failed to exhaust his administrative remedies as to several of his claims. [Filing No. 10 at 6-9.] The Court first addresses the exhaustion issue before turning to Mr. Hunter's claims. A. Failure to Exhaust The Respondent contends that Mr. Hunter did not exhaust his administrative remedies regarding his claims that he was denied an impartial decisionmaker, that he was denied evidence and witnesses, and that insufficient evidence supported the charge. [Filing No. 10 at 7.] The Respondent asserts that Mr. Hunter only raised an issue with a lack of detail in the Conduct Report on appeal. [Filing No. 10 at 8.] It contends that Mr. Hunter has procedurally defaulted on his remaining claims. [Filing No. 10 at 9.] Mr. Hunter did not file a reply, but asserts in his Petition that he did not present the grounds raised in his Petition on appeal because "this facility lost all my legal mail and property when I

was moved to another dorm." [Filing No. 2 at 3-6.] It is well established that state prisoners must exhaust their available state remedies before challenging a prison disciplinary conviction in federal court. See Love v. Vanihel, 73 F.4th 439, 446 (7th Cir. 2023) (citing 28 U.S.C. § 2254(b)(1)(A), (C)).

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Bluebook (online)
HUNTER v. WARDEN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hunter-v-warden-insd-2024.