United States District Court, S.D. Illinois
MEMORANDUM AND ORDER
CLIFFORD J. PROUD UNITED STATES MAGISTRATE JUDGE
Todd Woolridge filed a petition for writ of habeas corpus
under 28 U.S.C. § 2241challenging the imposition of
sanctions against him, including the loss of good conduct
credit, pursuant to prison disciplinary proceedings. (Doc.
Facts and Procedural History§
was convicted in the District Court for the Western District
of Missouri of failing to register as a sex offender. In
March 2014, he was sentenced to thirty months imprisonment,
to be followed by five years of supervised release.
United States v. Woolridge, Case No. 13-cr-242-BP,
Western District of Missouri.
January 4, 2015, when petitioner was assigned to FCI
Greenville, a correctional officer wrote an incident report
charging petitioner with possession of a weapon. This report
was based on the presence of a homemade weapon behind the
light above the sink in petitioner's cell. Petitioner and
two other inmates shared that cell. A hearing was held on
January 27, 2015, and petitioner was found guilty. As is
relevant here, he was sanctioned with the loss of forty-one
days of good conduct time. See, Doc. 1, pp.
filed an administrative remedy (grievance) and, as a result,
the incident report was returned to the institution for
reconsideration. Doc. 18, Ex. 2, p. 23.
hearing was held in May 2015, and Woolridge was again found
guilty and sanctioned with the loss of forty-one days of good
conduct time. Woolridge was transferred to a halfway house
sometime between the return of the incident report for
reconsideration and the second hearing. Doc. 26, Ex. 1 &
began serving his sentence of supervised release in October
2015. See, Doc. 27.
for Habeas Relief
habeas petition, Woolridge challenges the sufficiency of the
evidence presented at the January 2015 hearing. See, order on
preliminary review, Doc. 6.
petition must be dismissed because it is moot.
retain due process rights in connection with prison
disciplinary proceedings, but such proceedings “are not
part of a criminal prosecution, and the full panoply of
rights due a defendant in such proceedings does not
apply.” Wolff v. McDonnell, 94 S.Ct. 2963,
2975 (1974). The minimum requirements of due process in such
proceedings are (1) receipt of written notice of the charges
in advance of the hearing, (2) an opportunity to be heard
before an impartial decision maker, (3) the right to call
witnesses and present evidence where same will not be unduly
hazardous to safety or correctional goals, and (4) a written
statement as to the evidence relied on and the reason for the
decision. Wolff, 94 S.Ct. at 2978-2980;
Henderson v. U.S. Parole Commission, 13 F.3d 1073,
1077 (7th Cir. 1994).
findings of the disciplinary hearing officer must be
supported by “some evidence in the record.”
Superintendent v. Hill, 105 S.Ct. 2768, 2773 (1985).
The evidence need not be sufficient to logically exclude any
result except the one reached by the prison decision maker.
Viens v. Daniels, 871 F.2d 1328, 1334-1335 (7th Cir.
1989). In addition, only evidence that was presented to the
hearing officer is relevant to the ...