Summary Judgment of Tennessee Prisoner's Appeal of Disciplinary Ruling
Reversed

In this case involving a prison disciplinary proceeding, the Tennessee
Court of Appeals held that material factual disputes surrounding a
prisoner's waiver of his right to 24-hour notice and whether he was
permitted to call an exculpatory witness precluded summary judgment.
Hilton G. Jeffries, a Tennessee state prisoner, received four disciplinary
charges stemming from his relationship with a female guard, Shelby A.
Frazier. An investigation at the Southeastern Tennessee State Regional
Correctional Facility in Pikeville found that Frazier had allowed Jeffries
to make calls on her cell phone, provided him with writing supplies
purchased from local retailers, and made copies for him on a prison
copier. Prison officials subsequently charged Jeffries with possession of
contraband, abuse of telephone privileges, solicitation of staff, and
larceny (for acquiring office supplies and using a state-owned copy
machine). Jeffries pleaded guilty to all but the larceny charge.

The disciplinary board conducted a hearing on the larceny charge and found
Jeffries guilty. Jeffries was ordered to pay $810 in restitution for the
office supplies and the cost of the copies, and sentenced to five days in
punitive segregation. Jeffries then filed a petition for common-law writ
of certiorari on February 16, 2001, alleging that his three guilty pleas
were coerced. Jeffries also contended that the disciplinary board had
violated the Department's Uniform Disciplinary Procedures by not giving
him 24 hours notice of the charges and then forcing him to "proceed with
the hearing even after he refused to waive his right to notice" and
denying him the opportunity to present exculpatory evidence.

On September 5, 2001, the trial court granted the Department's motion for
summary judgment and dismissed Jeffries' petition without explanation.
Jeffries appealed.

The Court of Appeals affirmed the dismissal of Jeffries' claims regarding
the three guilty pleas, but reversed the dismissal of his claim
surrounding his conviction on the larceny charge, holding:

1) Ordinarily in cases involving common-law writs of certiorari, "once
the complete record has been filed, the reviewing court may" simply
determine whether the petitioner is entitled to relief without further
proceedings. However, when considering motions for summary judgment -- the
route the Department for some reason chose in this instance -- the trial
court is prohibited by Tenn.R.Civ.P., Rule 56 from granting the motion "if
the record contains material factual disputes." Therefore, in this
case, "the Department must dance by the tune it has asked the piper to
play."

2) Even if Jeffries was threatened with harsher punishment if he did not
plead guilty, Jeffries still "made a knowing and rational choice to plead
guilty in order to receive more lenient punishment," and is therefore in
no position to challenge the voluntariness of his three guilty pleas.

3) Tennessee prisoners have a property interest in their trust fund
accounts, and the "prison disciplinary board must follow all applicable
procedural rules when it imposes a money judgment against an inmate if the
judgment deprives the prisoner of a property interest."

4) "The Department failed to demonstrate the absence of material factual
disputes regarding" whether Jeffries waived his rights to a 24-hour notice
and to present exculpatory evidence. Therefore, "the trial court erred by
granting the summary judgment dismissing Mr. Jeffries' challenge to his
conviction on the larceny infraction." See: Jeffries v. Tennessee
Department of Corrections, 108 S.W.3d 862 (Tenn. Ct. App. 2002).

Subscribe today

Already a subscriber? Login

Related legal case