Burns v. PA Department of Corrections, 642 F.3d 163

Burns challenged DOC disciplinary proceedings at SCI Graterford for allegedly requiring him to pay Mobley’s medical expenses from a misconduct finding; account assessment is a protected property interest.
Hearing Officer Canino convicted Burns based on confidential informants and statements, without independently viewing a videotape Burns requested; Mobley refused to testify.
DOC disciplinary framework allowed sanctions including payment of expenses and medical costs; Holloway-type procedures address monetary deductions from inmate accounts.
District court granted summary judgment to defendants; Third Circuit reversed in part, remanding to evaluate due process and remedies.
Court held due process violated when the hearing officer did not independently assess the evidence’s relevance, including failing to view a requested videotape; Mobley’s testimony denial was not per se a violation, and qualified immunity issues were analyzed.
Remedies included expunging the misconduct conviction but denying other relief post-PLRA considerations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Pre-deprivation process for evidence: must be independent relevance review	Burns argues Canino failed to independently assess evidence relevance.	Canino relied on police-like representations under prison policy.	Violation: independent relevance assessment required.
Right to call Mobley as a witness	Mobley should have testified despite safety/relational concerns.	Institutional concerns outweighed Burns' witness right.	No due process violation for Mobley’s non-testimony.
videotape request and documentary evidence	Evidence could exonerate Burns; due process requires production.	Discretion to limit evidence based on safety and relevance.	Due process violated when evidence not independently evaluated for relevance.
Qualified immunity	Officials should have known assessing accounts without due process violated law.	No clearly established precedent at the time for this exact scenario.	Officials entitled to qualified immunity.
Remedies for due process violation	Remedies should reverse the misconduct and address harms.	Remedies must be narrowly tailored; avoid windfalls.	Misconduct expunged; other remedies denied to avoid windfall.

Wolff v. McDonnell, 418 F.2d 539 (1974) (due process in prison disciplinary hearings; right to notice and a hearing; evidentiary protections)
Reynolds v. Wagner, 128 F.3d 166 (3d Cir. 1997) (prisoners have property interests in funds held in prison accounts; due process protections)
Holloway v. Lehman, 671 A.2d 1179 (Pa. Cmwlth. 1996) (state court Holloway hearing required for monetary deductions from inmate accounts)
Dalton v. Hutto, 713 F.2d 75 (4th Cir. 1983) (right to present witnesses; concerns about compelling voluntary testimony; due process validation)
Carey v. Piphus, 435 U.S. 247 (1978) (burden-shifting framework for assessing damages when due process is violated)