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Mental State Matters, But Not a Defense, In Prison Disciplinary Proceeding

On October 16, 1990, the Court of Appeals of New York held that, although a prison disciplinary hearing officer must consider the prisoner's mental state as a potential mitigation factor for punishment, mental state was not an affirmative defense to prison disciplinary charges.
Samuel Huggins, a New York state prisoner, received numerous disciplinary charges after participating in an "incident" on the prison yard. At the Superintendent's hearing, Huggins claimed that he was having a nervous breakdown and not in his right mind at the time of the incident. He was found guilty of the misconduct and punished. Huggins appealed the decision under CPLR article 78.

The Appellate Division of the Supreme Court noted that Huggins had not cited any authority that mental state was an affirmative defense to prison disciplinary charges. The Appellate Division found that the prisoner's mental state was relevant and material evidence in mitigation of the penalty and possibly as an excuse for the misconduct.
Therefore the disciplinary officer must consider such evidence. It also held that the disciplinary officer has given Huggins a full and complete opportunity to develop such evidence and had taken said evidence into consideration when punishing Huggins. Therefore, the Appellate Division confirmed the guilty disciplinary determination of the Commissioner of Correctional Services and dismissed the petition. Huggins appealed to the Court of Appeals.

The Court of Appeals held that, "in the context of a prison disciplinary hearing in which the prisoner's mental state is at issue, a Hearing Officer is required to consider evidence regarding the prisoner's mental condition." It also held that the hearing officer in this case did so. Therefore, it upheld the judgment of the Appellate Division without costs. Sec: Matter of Huggins v. Coughlin, 76 N.Y.2d 904; 563 N.E.2d 281; 561 N.Y.S.2d 910 (NY 1990).

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Related legal case

Matter of Huggins v. Coughlin