Eric Grandberry v. Brian Smith
754 F.3d 425
7th Cir.2014Background
- Grandberry, head inmate law clerk at Putnamville, used library computers to download legal materials for other prisoners and assisted staff.
- Librarian directed him to fill a petition to stop child support; another staffer asked for divorce forms; he completed these tasks.
- April 2011: library computers sent to police crime lab; data showed Grandberry's activity; charged with offense 207, unauthorized possession of an electronic device.
- Disciplinary board revoked 30 days of good-time credits; Grandberry sought habeas corpus relief under 28 U.S.C. §2254; district court denied; panel held no COA required; Walker v. O’Brien followed.
- Court concluded Grandberry’s conduct was authorized because staff directed/allowed it under prison regulations, and there was no evidence supporting the alleged unauthorized use; remedy was to reverse and remand with instructions to restore good-time credits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there 'some evidence' supporting the good-time revocation? | Grandberry lacked evidence. | Indiana maintained evidence supported the offense. | There was no evidence. |
| Was Grandberry's conduct 'unauthorized' given staff authorization? | Staff authorization should negate unauthorized-use charge. | Authorization did not apply to this interpretation. | Conduct was authorized; charge invalid. |
| Did prison due-process requirements apply and were they met (Wolff/Hill standards)? | Due process violated by lack of full investigative report and notice. | Procedural safeguards not properly disclosed; staff directives mattered. | Due process not satisfied; remand for restoration of credits. |
| What is the appropriate remedy for loss of good-time credits given the error? | Restore good-time credits. | Remedial actions not specified other than original revocation. | Remand with writ to restore good-time credits. |
Key Cases Cited
- Wolff v. McDonnell, 418 U.S. 539 (U.S. (1974)) (due-process standard for disciplinary sanctions in prisons requires some evidence)
- Superintendent of Walpole v. Hill, 472 U.S. 445 (U.S. (1985)) ('some evidence' standard for revoking good-time credits)
- Walker v. O’Brien, 216 F.3d 626 (7th Cir. 2000) (regarding COA requirement in good-time cases)
- United States v. Bailey, 444 U.S. 394 (U.S. (1980)) (duress/necessity concepts cited in context of authorization)