Servin v. Rivers

CourtDistrict Court, N.D. Texas
DecidedSeptember 19, 2024
Docket3:23-cv-01127
StatusUnknown

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

Bluebook
Servin v. Rivers, (N.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

JUAN JOSE SERVIN, § #24486-179, § PETITIONER, § § V. § CASE NO. 3:23-CV-1127-X-BK § C. RIVERS, § RESPONDENT. §

FINDINGS, CONCLUSIONS AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

Pursuant to 28 U.S.C. § 636(b) and Special Order 3, Juan Jose Servin’s pro se petition for habeas corpus under 28 U.S.C. § 2241 was referred to the undersigned United States Magistrate Judge for case management, including entry of findings and a recommended disposition. As detailed here, the petition should be DENIED, and this case should be DISMISSED WITH PREJUDICE. I. BACKGROUND Servin, a federal prisoner at the Federal Correction Institution (FCI) in Seagoville, Texas, challenges a prison disciplinary proceeding—specifically, the resulting loss of good time credit. Doc. 3 at 3. On October 23, 2021, Servin was given a copy of an incident report alleging that on that day, he possessed a hazardous tool (a cellular phone), in violation of the Federal Bureau of Prisons (BOP) disciplinary code. Doc. 9 at 13–18. During an investigation, also conducted that day, Servin was advised of his right to remain silent, after which Servin stated, “I don’t know anything about a cell phone Lou [Lieutenant]. That is not mine and I don’t know who put it there but Lieutenant that is not mine. I am not taking responsibility for that phone that [is] not mine.” Doc. 9 at 18. Ultimately, the charge was referred to the Discipline Hearing Officer (DHO) for “disposition.” Doc. 9 at 17. On October 27, 2021, Servin was informed of his rights in relation to a disciplinary hearing and any subsequent administrative appeals. Doc. 9 at 22. Servin waived in writing his

rights to have a staff representative and present witnesses at the disciplinary hearing. Doc. 9 at 24–25. Servin appeared before the DHO on November 4, 2021. Doc. 9 at 24. In a subsequent written report, the DHO recounted the evidence presented in the incident report. [O]n 10/23/2021 at approximately 10:55 A.M. staff conducted a search of cell 204 in unit E-A. Upon entering the cell it was observed that Inmate SERVIN, JUAN, #24486-179 was sitting on his bed, E02-041L. Inmate SERVIN was instructed to exit the cell and submit to a search to which he complied. I, officer K. Johnson, discovered a blue in color AT&T cell phone attached to Inmate SERVIN[’S] bedframe, E02-041l, via a magnet. Staff also discovered a white in color LG phone charger plugged into the outlet behind inmate SERVIN[’S] bed, E02-041L.

[Servin] stated to the UDC [Unit Disciplinary Committee], the phone does not belong to [Servin]. [Servin] elected not to make a statement to the DHO.

Doc. 9 at 25–26. The DHO concluded that “the greater weight of the evidence, eye witness [sic] account of the incident, Photo sheet and written report. . . convinced [him]” that “[Servin] committed the prohibited act of Possession, Introduction of a Hazardous Tool (cellphone). . . .” Doc. 9 at 26. As punishment, the DHO disallowed 41 days of Servin’s good conduct time credit, imposed 15 days of disciplinary segregation, and suspended Servin’s commissary, telephone and visiting privileges for 90 days. Doc. 9 at 26. In his habeas petition, Servin asserts his actual innocence of the infraction. Doc. 3 at 7. He contends he “had no possession, control, or use of the cell phone.” Doc. 3 at 9. He relies on

2 an affidavit of his cell mate, David Cerna, who was subject to the same cell search as Servin. Doc. 3 at 8. In the January 26, 2022, affidavit, Cerna admitted that drugs were found in his possession and stated that he “accepted responsibility” for possession of the cellular phone that gave rise to Servin’s disciplinary proceeding.1 Doc. 3 at 18. As relief, Servin requests that the Court “overturn the erroneous conviction and order [his] good time credits restored and expunge

the incident from the record.” Doc. 3 at 10. Respondent argues the petition lacks merit. Doc. 8. Servin has not filed a reply. Upon review, the Court concludes that at least some evidence supports Servin’s disciplinary conviction. Thus, his claim fails. II. APPLICABLE LAW BOP authorities may award credit to inmates against their prison sentences as a reward for good behavior. 18 U.S.C. § 3624(b). An inmate may not be deprived of these so-called “good time credits” for a disciplinary violation unless afforded due process. Wolff v. McDonnell, 418 U.S. 539, 570 (1974). Due process is satisfied when the inmate is given (1) advance written

notice of the charges, (2) the opportunity to appear and call witnesses, (3) the opportunity, in certain situations, for the assistance of a fellow inmate or staff, and (4) a written statement by the fact finder of the evidence relied on for the decision. Id. at 563–70. Federal prisoners may contest the loss of good time credits under 28 U.S.C. § 2241, which is the proper procedural vehicle for a prisoner to challenge “the execution of his sentence rather than the validity of his conviction and sentence.” United States v. Cleto, 956 F.2d 83, 84 (5th Cir. 1992).

1 Servin did not submit Cerna’s affidavit until his regional administrative appeal. Doc. 3 at 29; Doc. 3 at 36.

3 In reviewing an institution’s disciplinary actions, the Court need only consider if the decision was supported by “some basis in fact” or “a modicum of evidence.” Superintendent Massachusetts Corr. Institution v. Hill, 472 U.S. 445, 454–56 (1983); see also Smith v. Rabalais, 659 F.2d 539, 545 (5th Cir. 1981) (citation omitted) (court should consider whether disciplinary action is “supported by ‘some facts’ ‘whether any evidence at all’ supports the action taken by

the prison officials.”). Federal court intervention is appropriate only when the prison official’s action is “arbitrary or capricious[.]” Reeves v. Pettox, 19 F.3d 1060, 1062 (5th Cir. 1994). Moreover, the evidence need not eliminate all other conclusions, nor does the “some evidence” standard require a weighing of the evidence or an independent assessment of witness credibility. Hill, 472 U.S. at 455–56. An incident report alone can constitute some evidence. See Hudson v. Johnson, 242 F.3d 534, 536–37 (5th Cir. 2001). III. ANALYSIS Servin has not alleged a due process violation. That notwithstanding, the Court finds he was afforded all required due process during his disciplinary proceedings. As recounted supra,

Servin received written notice of the allegations and was advised of his right to have a staff representative and to call witnesses at the hearing before the DHO (which he declined) and, following the November 4, 2021, disciplinary hearing, was provided a copy of the written decision that summarized the evidence on which the DHO relied, on January 10, 2022. Doc. 9 at 20, 22, 24–26.

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Related

Reeves v. N.A. Pettcox
19 F.3d 1060 (Fifth Circuit, 1994)
Hudson v. Johnson
242 F.3d 534 (Fifth Circuit, 2001)
Boyd Flannagan v. Rebecca Tamez
368 F. App'x 586 (Fifth Circuit, 2010)
Wolff v. McDonnell
418 U.S. 539 (Supreme Court, 1974)
Charles Smith v. Fulton Rabalais, Jr.
659 F.2d 539 (Fifth Circuit, 1981)
United States v. Jose Cleto
956 F.2d 83 (Fifth Circuit, 1992)
Stanley Pruitt v. Mark Martin
582 F. App'x 319 (Fifth Circuit, 2014)

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Servin v. Rivers, Counsel Stack Legal Research, https://law.counselstack.com/opinion/servin-v-rivers-txnd-2024.