Seventh Circuit Reverses Denial of Prisoner’s Claim for Failure to Detach Portion of Administrative Form
Charles Donelson was a prisoner in the custody of the Illinois Department of Corrections (IDOC) when he was charged with disciplinary infractions for two incidents involving the same guard. Donelson denied that he had tried to leave his housing unit without permission, failed to follow the guard’s warning and then later attacked him. Following a disciplinary hearing in which prison officials did not produce witnesses and evidence requested by Donelson, including footage from video surveillance cameras, he was found guilty. As a result he lost a year of accumulated “good time” credit.
After exhausting his administrative remedies, Donelson filed a petition for writ of mandamus in state court challenging the denial of evidence and witnesses. His petition was denied and the denial affirmed by a state appellate court, which held for the first time that Donelson had failed to properly detach the bottom portion of an administrative form identifying what witnesses he was requesting at the disciplinary hearing; instead, he had submitted the entire form. See: Donelson v. Godinez, 2013 IL App (4th) 120795-U (Ill. App. Ct. 4th Dist. 2013).
Donelson then filed a claim for federal habeas relief under Section 2254, alleging that he had been denied due process during the disciplinary proceedings. The federal district court rejected his habeas petition, partly on the merits and partly on procedural grounds.
Donelson appealed and on January 28, 2016 the Seventh Circuit affirmed the partial ruling on the merits but vacated the procedural ruling, finding that the state appellate court’s decision “carried bureaucratic concerns about paperwork to an unreasonable extreme and [did] not bar federal consideration of the prisoner’s constitutional claim on the merits.”
The Court of Appeals further noted that prison officials had failed to produce any legal precedent to justify their non-production of the requested witnesses and evidence but for Donelson’s failure to detach the bottom part of the form. “The state appellate court did not cite, the respondent does not identify, and we have not found any Illinois law, regulation, or precedent requiring inmates, on penalty of loss of their right to be heard, to detach and submit only the bottom portion of the form,” the Court wrote.
The Seventh Circuit also rejected the state’s argument that depriving prisoners of witnesses and evidence for failure to detach the bottom part of the form had been an established procedure in the disciplinary process. Accordingly, as the state court had not relied on an adequate state-law ground when dismissing Donelson’s claims, the Seventh Circuit reviewed the actions of the IDOC disciplinary committee “without any deference to the state court’s decision.”
The federal district court’s order was vacated and the case remanded for further proceedings, where it remains pending. See: Donelson v. Pfister, 811 F.3d 911 (7th Cir. 2016).
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Related legal cases
Donelson v. Pfister
|Cite||811 F.3d 911 (7th Cir. 2016)|
|Level||Court of Appeals|
Donelson v. Godinez,
|Cite||2013 IL App (4th) 120795-U (Ill. App. Ct. 4th Dist. 2013).|