Personal Restraint Petition of Jose Antonio Contreras

Court of Appeals of Washington·Decided November 1, 2022·No. 38357-1·Unpublished

Opinion

FILED NOVEMBER 1, 2022 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

In the Matter of the Personal Restraint of: ) No. 38357-1-III ) JOSE ANTONIO CONTRERAS, ) ORDER GRANTING MOTION ) FOR RECONSIDERATION Petitioner. )

THE COURT has considered petitioner Jose Antonio Contreras’s motion for

reconsideration of our July 28, 2022, opinion; the answer/response of the Department of

Corrections; and the record and file herein.

IT IS ORDERED that the motion for reconsideration is granted.

IT IS FURTHER ORDERED that this court’s July 28, 2022, opinion is withdrawn

and a new opinion is filed herewith.

PANEL: Judges Pennell, Siddoway and Fearing.

FOR THE COURT:

___________________________________ LAUREL H. SIDDOWAY Chief Judge FILED NOVEMBER 1, 2022 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

In the Matter of the Personal Restraint of: ) No. 38357-1-III ) JOSE ANTONIO CONTRERAS, ) UNPUBLISHED OPINION ) Petitioner. )

PENNELL, J. — Jose Antonio Contreras has filed a personal restraint petition,

arguing he is subject to illegal restraint as the result of a prison disciplinary decision that

resulted in the deprivation of good time credits. We grant the petition and remand for a

new disciplinary hearing.

FACTS

Mr. Contreras is incarcerated at the Airway Heights Corrections Center. On

April 15, 2021, Mr. Contreras was issued a serious infraction for quitting his assigned

security crew job the previous day. A hearing on the infraction was eventually scheduled

for June 11, 2021. 1

On May 12, 2021, the Department of Corrections (Department) issued a

memorandum to all staff announcing an interim policy that required hearing officers to

1 The hearing was initially scheduled to take place on May 11, 2021, but was continued at Mr. Contreras’s request to allow him an opportunity to submit written questions to the corrections officer who made the infraction report. No. 38357-1-III In re Pers. Restraint of Contreras

reduce serious infractions to lesser infractions when applicable. The memorandum stated

it was “in effect immediately.” Pet’r’s Mot. to Amend Pers. Restraint Pet., App. I, In re

Pers. Restraint of Contreras, No. 38357-1-III (Wash. Ct. App. Nov. 22, 2021).

The May 12 memorandum was prompted by an Office of Corrections Ombuds

(OCO) investigation regarding an inmate who received a major infraction for refusing to

work due to COVID-19 health and safety concerns. In an April 28 report, the OCO

recommended that all similar past infractions be reviewed and possibly reduced or

removed. The OCO also recommended that, going forward, Department policy “be

revised to include direction that hearing officers will reduce major infractions to lesser

infractions if applicable.” Id. In correspondence dated May 12 from the Department to the

OCO, the Department responded that it had “agreed to and completed review of all

serious infractions issued for COVID-19 related concerns from May 1, 2020, to March

16, 2021,” in order to determine if the infractions should be overturned. Id. From that

point on, the Department agreed to recommend amendments to its disciplinary policy and,

pending the amendment process, to issue an immediate directive. The immediate directive

was the May 12 all-staff memorandum, referenced in the preceding paragraph.

At his June 2021 hearing, Mr. Contreras claimed he quit his job over COVID-19

health and safety concerns. He explained the van used to transport his work crew was too

2 No. 38357-1-III In re Pers. Restraint of Contreras

small to allow for appropriate social distancing. According to Mr. Contreras, the people

inside the van were so close they were “pretty much touching.” Id., App. E at 6. Mr.

Contreras noted that he had not been vaccinated, but he previously had contracted

COVID-19 and did not want to get sick again. Mr. Contreras conceded that the occupants

of the work van all wore masks. Mr. Contreras brought the April 28 OCO report to the

attention of the hearing officer, who indicated she has already seen it.

The hearing officer appeared to express some doubt about the validly of

Mr. Contreras’s COVID-19 concerns. The officer noted she had been inside the type

of transport van referenced by Mr. Contreras and the people inside the vans “definitely

[were] not touching each other.” Id. The officer noted the occupants of Mr. Contreras’s

van were wearing masks and that Mr. Contreras had previously contracted COVID-19.

The officer found Mr. Contreras guilty and imposed 15 days loss of good time, 30 days

loss of recreation privileges, two months loss of monthly packages, and one month earned

time not earned. The hearing officer noted that the sanction was mandatory but, in

apparent reference to the April 28 OCO report and May 12 response of the Department,

she stated “headquarters” could make a different determination if it decided “to overturn

these.” Id. at 7.

3 No. 38357-1-III In re Pers. Restraint of Contreras

Mr. Contreras immediately appealed the hearing officer’s decision to the prison

superintendent. He again referenced the OCO report and the Department’s response,

including the interim policy. The associate superintendent issued a response to

Mr. Contreras’s appeal on July 16, 2021, upholding the disposition. According to the

associate superintendent, the Department’s COVID-19 policy did not apply to Mr.

Contreras’s case. The decision stated, “[t]he department did agree to complete a review

of . . . [serious] infractions that were issued for COVID related issues from March 1st

through March 16th and to determine if they were appropriate to be overturned. Your

infraction was in April 2021 and met” the criteria for a mandatory infraction. Id., App. J

at 1.

Mr. Contreras subsequently filed this timely personal restraint petition, challenging

his disciplinary sanction.

ANALYSIS

To obtain relief from a prison disciplinary sanction, a petitioner must show they

have been subject to unlawful restraint. RAP 16.4(a)-(c). Restraint is unlawful if “[t]he

conditions or manner of the restraint of petitioner are in violation of the Constitution of

the United States [of America] or the Constitution or laws of the State of Washington.”

RAP 16.4(c)(6). Improper deprivation of good time credits can support an inmate’s claim

4 No. 38357-1-III In re Pers. Restraint of Contreras

of unlawful restraint. In re Pers. Restraint of Reifschneider, 130 Wn. App. 498, 501,

123 P.3d 496 (2005).

Mr. Contreras contends he is under unlawful restraint because the Department

failed to abide by its own “rules or regulations” regarding COVID-19 related infractions

in issuing his disciplinary sanction. In re Pers. Restraint of Wilson, 17 Wn. App. 2d 72,

82, 484 P.3d 1 (2021). We agree.

Both the hearing officer and the associate superintendent handling Mr. Contreras’s

appeal failed to appreciate that the May 12, 2021, interim policy arising out of COVID-19

health and safety concerns was effective immediately and was therefore applicable to

Mr. Contreras’s case. Contrary to what was stated by the hearing officer, the COVID-19

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

Personal Restraint Petition of Jose Antonio Contreras, (Wash. Ct. App. 2022).

Personal Restraint Petition of Jose Antonio Contreras (Personal Restraint Petition of Jose Antonio Contreras) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

In re the Personal Restraint of Reifschneider
123 P.3d 496 (Court of Appeals of Washington, 2005)