GERHARDT v. KNIGHT, 1:17-cv-00702

Petitioner Adam Gerhardt, an Indiana inmate, was charged in disciplinary case CIC 16-11-0024 under IDOC ADP § B-220 (unauthorized financial transaction) based on a monitored phone call.
Intelligence Analyst Courtney Foust reported that another inmate, Dustin Padgett, told his father to send a $150 Walmart card “for AG” and provided a phone number the analyst linked to Gerhardt.
Gerhardt pleaded not guilty, requested Padgett’s statement and phone-record evidence; Padgett later denied asking his father to send money to Gerhardt and said he had used another peer’s number.
At the hearing the officer considered the conduct report, Padgett’s written answer, and Gerhardt’s statement denying involvement; the officer found Gerhardt guilty and revoked 30 days of earned credit time.
Administrative appeals were denied; Gerhardt filed a § 2254 habeas petition raising only a sufficiency-of-the-evidence claim.
The court reviewed the record (including the full phone call ex parte) and concluded there was “some evidence” supporting the disciplinary conviction; the habeas petition was denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence supporting a B-220 (unauthorized financial transaction) conviction met the due-process "some evidence" standard	Gerhardt: record lacks evidence he personally engaged in the transaction; no preponderance of evidence that he was involved	Respondent: phone call connected the transaction to initials "AG" and a phone number linked to Gerhardt, providing evidence supporting the finding	Court: Affirmed—"some evidence" existed (phone number link + initials + context); habeas denied

Cochran v. Buss, 381 F.3d 637 (7th Cir. 2004) (prisoners cannot be deprived of good-time credits without due process)
Montgomery v. Anderson, 262 F.3d 641 (7th Cir. 2001) (due-process protections for loss of credit-earning class)
Superintendent, Mass. Corr. Inst. v. Hill, 472 U.S. 445 (U.S. 1985) (disciplinary findings require "some evidence")
Wolff v. McDonnell, 418 U.S. 539 (U.S. 1974) (due-process protections in prison disciplinary proceedings)
Piggie v. Cotton, 344 F.3d 674 (7th Cir. 2003) (procedural due-process standards in prisoner discipline)
Webb v. Anderson, 224 F.3d 649 (7th Cir. 2000) (scope of procedural protections in prison discipline)
Ellison v. Zatecky, 820 F.3d 271 (7th Cir. 2016) ("some evidence" standard requires any record evidence that could support the decision)
Eichwedel v. Chandler, 696 F.3d 660 (7th Cir. 2012) (explaining "some evidence" suffices in prison disciplinary appeals)
Moffat v. Broyles, 288 F.3d 978 (7th Cir. 2002) ("some evidence" is less demanding than preponderance or beyond reasonable doubt)