945 F.3d 159
4th Cir.2019Background
- Casey Tyler, a North Carolina state prisoner, filed an administrative complaint alleging a prison guard (Cameron Gaddy) groped him during a pat-down after chapel; the allegation was investigated and deemed "unfounded."
- After that determination, prison staff charged Tyler under North Carolina Disciplinary Procedure A-18 (making a knowingly false allegation against staff); written statements from the reporting officer, the investigating officer, and Officer Gaddy were submitted to the disciplinary hearing officer (DHO).
- Tyler requested the surveillance video from the incident be made part of the hearing record; the Investigating Officer reviewed the video and reported it "neither took away nor added" to the reporting party’s statement, but the DHO did not personally view the video at the hearing and instead relied on the Investigating Officer’s report.
- The DHO found Tyler guilty and revoked 20 days of earned good-time credits; state courts denied relief without opinions and the federal district court granted the State summary judgment denying Tyler’s § 2254 petition.
- The Fourth Circuit granted a limited COA on two issues: (1) whether the DHO erred by not personally reviewing/introducing the surveillance video, and (2) whether the record contained "some evidence" to support Tyler’s A-18 conviction.
- The court affirmed denial of relief on the video-review claim (no clearly established Supreme Court rule required DHO review at the time) but vacated and remanded on the sufficiency-of-evidence claim, concluding the record lacked any probative evidence of the requisite mens rea and directing restoration of Tyler’s lost good-time credits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| DHO did not personally review/introduce surveillance video | DHO violated due process by deferring to the Investigating Officer and refusing to personally view potentially exculpatory video | No clearly established Supreme Court rule required a DHO to personally view video; Investigating Officer reviewed it and reported no material impact | Affirmed: state-court denial was not an unreasonable application of Supreme Court precedent; no clearly established right at time of state decision |
| Insufficiency of evidence for A-18 conviction (knowingly false allegation) | Record contains no probative evidence that Tyler knowingly made a false allegation or knew it could expose officer to criminal liability | Investigating Officer’s report, Officer Gerald’s statement, and Gaddy’s statement provide "some evidence" supporting the conviction | Vacated: record lacks any minimal probative evidence of mens rea; "some evidence" standard not met; grant habeas relief restoring good-time credits |
Key Cases Cited
- Wolff v. McDonnell, 418 U.S. 539 (1974) (establishes due process protections for prison disciplinary proceedings involving loss of good-time credits)
- Superintendent, Mass. Corr. Inst. v. Hill, 472 U.S. 445 (1985) (requires only "some evidence" to support disciplinary findings revoking good-time)
- Lennear v. Wilson, 937 F.3d 257 (4th Cir. 2019) (held hearing officer, not charging officials, must decide denial of access to surveillance video; recognized as a new extension of Wolff)
- Young v. Lynch, 846 F.2d 960 (4th Cir. 1988) (refused to infer a clearly established right to production of physical evidence in every prison disciplinary hearing)
- Baker v. Lyles, 904 F.2d 925 (4th Cir. 1990) (examples of circumstantial and informant evidence satisfying the "some evidence" standard)
- Harrington v. Richter, 562 U.S. 86 (2011) (explains AEDPA’s highly deferential standard to state-court decisions)