Miguel De Paula Arias v. Warden FCI Williamsburg

CourtCourt of Appeals for the Fourth Circuit
DecidedApril 26, 2024
Docket22-6836
StatusUnpublished

This text of Miguel De Paula Arias v. Warden FCI Williamsburg (Miguel De Paula Arias v. Warden FCI Williamsburg) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miguel De Paula Arias v. Warden FCI Williamsburg, (4th Cir. 2024).

Opinion

USCA4 Appeal: 22-6836 Doc: 16 Filed: 04/26/2024 Pg: 1 of 16

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 22-6836

MIGUEL DE PAULA ARIAS,

Petitioner - Appellant,

v.

WARDEN FCI WILLIAMSBURG,

Respondent - Appellee.

Appeal from the United States District Court for the District of South Carolina, at Florence. Henry M. Herlong, Jr., Senior District Judge. (4:21-cv-02962-HMH)

Submitted: April 18, 2024 Decided: April 26, 2024

Before AGEE and THACKER, Circuit Judges, and KEENAN, Senior Circuit Judge.

Vacated and remanded by unpublished per curiam opinion.

Miguel De Paula Arias, Appellant Pro Se. Cate Cardinale, Assistant United States Attorney, Marshal Prince, II, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Columbia, South Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 22-6836 Doc: 16 Filed: 04/26/2024 Pg: 2 of 16

PER CURIAM:

Miguel De Paula Arias, a federal inmate, appeals the district court’s order accepting

the recommendation of the magistrate judge; granting summary judgment in favor of

Respondent, the Warden of Federal Correctional Institution Williamsburg; and dismissing

De Paula Arias’ 28 U.S.C. § 2241 petition challenging a decision of a Disciplinary Hearing

Officer (“DHO”). When granting summary judgment, the district court concluded that the

magistrate judge did not clearly err in denying De Paula Arias’ motion for leave to conduct

discovery. De Paula Arias challenges that decision, too. We vacate the district court’s

order and remand so that De Paula Arias may conduct the discovery necessary to resolve

his § 2241 petition.

I.

On October 15, 2019, prison employee Magdeline Mirabal submitted Incident

Report Number 3316154 accusing De Paula Arias of “strok[ing] [her] right bottom behind

from bottom to top.” (E.R. 105 (internal quotation marks omitted)). * This incident

occurred at approximately 11:30 a.m. near the commissary area of the prison yard. Based

on Mirabal’s report, De Paula Arias was charged with violating Code 229, a “[s]exual

assault of any person, involving non-consensual touching without force or threat of force”

(“Code 229 incident report”). (E.R. 105). De Paula Arias did not receive a copy of the

Code 229 incident report right away because the case had been referred to the Federal

Bureau of Investigation (“FBI”) for possible criminal prosecution. On November 13, 2019,

* Citations to “E.R.” refer to the electronic record filed in this court.

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at 7:25 p.m., after the FBI deferred the case, Lieutenant D. Davis delivered the Code 229

incident report to De Paula Arias. De Paula Arias proclaimed his innocence and confirmed

that he understood his due process rights. D. Davis then referred the case to the Unit

Discipline Committee (“UDC”) for a hearing and noted that the Code 229 incident report

was related to Incident Report Number 3327755, though he did not provide any other

information about the related report. De Paula Arias maintained his innocence before the

UDC, and, due to the severity of the charge, the UDC referred the case to DHO R. Hudson

on November 14, 2019, at 10:50 a.m.

At the hearing before Hudson on November 18, 2019, De Paula Arias waived his

right to the assistance of a staff representative but requested fellow inmate Mark Winnick

as a witness. According to Hudson’s report, Winnick testified, “I was following Aries [sic]

out of the unit. I did not see anything,” and De Paula Arias testified, “I deny this

completely. It is not in my DNA.” (E.R. 111 (internal quotation marks omitted)). Hudson

also reported that De Paula Arias did not present any documentary evidence. Based on

Mirabal’s report and his assessment of Mirabal’s and De Paula Arias’ credibility, Hudson

concluded that the greater weight of the evidence supported the finding that De Paula Arias

violated Code 229. Hudson sanctioned De Paula Arias to a day in disciplinary segregation,

the loss of 27 days of good conduct time, and 180 days without email, visitation, and

commissary privileges.

During his administrative appeals, De Paula Arias faulted Hudson for failing to

consider Winnick’s written declaration, deliberately misstating Winnick’s testimony in the

report, and failing to consider the Special Investigative Services (“SIS”) report about the

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incident (“SIS incident report”). As for the latter contention, De Paula Arias explained that

his charge had been reduced after the SIS conducted its investigation because the primary

investigator, SIS Technician Kathleen Andino, concluded that Mirabal’s statement lacked

candor and was not supported by the witnesses Andino interviewed, including other staff

members. De Paula Arias attached the SIS incident report to his § 2241 petition, but the

Incident Report Number was absent or redacted on that document. According to the report,

the incident occurred on October 20, 2019, at approximately 11:30 a.m., near the

commissary area of the prison yard. The report also indicated that De Paula Arias admitted

to Andino that he walked behind Mirabal, crossed over the yellow line, and brushed his

left shoulder against Mirabal’s back. At the conclusion of the SIS investigation on

November 13, 2019, De Paula Arias was charged with violating “[C]ode 316, being in an

unauthorized area, [and] [C]ode 498, interfering with a staff member most like [C]ode 409,

unauthorized physical contact.” (E.R. 39).

D. Davis delivered the SIS incident report to De Paula Arias on November 13, 2019,

at 7:25 p.m. At the hearing before the UDC on November 14, 2019, around 10:30 a.m.,

De Paula Arias maintained that he accidentally brushed up against Mirabal as he was

walking through the crowded commissary area. Based on the SIS incident report and De

Paula Arias’ admission, the UDC found that De Paula Arias committed the prohibited acts

and sanctioned him to 30 days without phone privileges for violating Code 316 and to 30

days without visitation privileges for violating Code 498.

After his administrative appeals related to the Code 229 incident report were

unsuccessful, De Paula Arias filed a § 2241 petition in the district court, maintaining that

4 USCA4 Appeal: 22-6836 Doc: 16 Filed: 04/26/2024 Pg: 5 of 16

Hudson improperly refused to accept a copy of Winnick’s declaration, mischaracterized

Winnick’s testimony, and wrongfully failed to consider the SIS incident report.

Respondent moved for summary judgment, arguing that De Paula Arias received all the

process he was due under Wolff v. McDonnell, 418 U.S. 539 (1974), and that Hudson’s

decision should be upheld because it was supported by some evidence. Addressing the SIS

incident report, Respondent confirmed that the report “concern[ed] the same events at issue

in the instant case” but argued that the report was not helpful to De Paula Arias because “it

directly contradicts both his witness statement and his own statement and denial of guilt

during the DHO hearing.” (E.R. 100-01). That is, because De Paula Arias admitted to

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Miguel De Paula Arias v. Warden FCI Williamsburg, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miguel-de-paula-arias-v-warden-fci-williamsburg-ca4-2024.