Epperson v. Peck, 1:24-cv-01199

Kevin S. Epperson, an inmate at James T. Vaughn Correctional Center, filed a § 1983 civil rights suit pro se, alleging due process and defamation violations after a prison disciplinary hearing.
Epperson claimed Correctional Officer Tomlinson falsely accused him of threats, leading to a disciplinary hearing where he was found guilty and lost privileges for 30 days.
He alleged that the hearing officer was biased, relied solely on Tomlinson’s report, failed to consider exculpatory evidence (tablet/phone records), and did not allow him to confront his accuser.
Epperson also raised a defamation claim arising from these disciplinary proceedings.
The court screened his claims under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(a), applying a liberal standard given his pro se status.
Epperson sought further amendments, but the court found the amendments futile and denied leave while dismissing the complaint without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Officer failed to credit tablet/phone	Evidence of no research on officer not considered	Hearing officer not required to discuss all evidence	No due process violation
No opportunity to confront accuser	Right to confront Tomlinson at hearing denied	No right to confrontation in prison hearings	No due process violation
Decision based solely on disciplinary report	Reliance on Tomlinson's report was improper	"Some evidence" standard met by report	No due process violation; hearsay allowed
Bias of disciplinary hearing officer	Hearing officer was biased	No direct involvement alleged	No showing of actionable bias
Defamation claim	Plaintiff defamed during process	Defamation alone not actionable under § 1983	No actionable defamation; no supplemental jurisdiction

Ashcroft v. Iqbal, 556 U.S. 662 (complaint must plead facts showing plausibility)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (complaint must contain more than labels/conclusions)
Wolff v. McDonnell, 418 U.S. 539 (prisoners have limited procedural due process rights in hearings)
Superintendent, Massachusetts Corr. Inst., Walpole v. Hill, 472 U.S. 445 (disciplinary findings require 'some evidence')
Young v. Kann, 926 F.2d 1396 (no absolute right to cross-examine witnesses in prison disciplinary hearings)
Meyers v. Aldredge, 492 F.2d 296 (impartial tribunal requirement for disciplinary hearings)
Olim v. Wakinekona, 461 U.S. 238 (no constitutional right to be housed in a particular prison unit)