In re Marti CA3, C093153

Jan. 14, 2019: Officer J. Brown conducted a dorm search, documented an electric grill and various items listed as excess property; Sergeant M. Rhode reviewed Brown’s original rules-violation report.
The initial proceeding about the grill was later vacated and reissued; the January report remained in the record and was referenced thereafter.
May 5, 2019: Brown conducted another search and prepared a report charging Alex Marti with possession of excess property; the May report expressly referenced the January 14 report and Brown’s alleged verbal warning to Marti to come into compliance.
Marti filed a Form 22 and met with Rhode (the reviewer); Marti later denied Brown’s claimed warning and asserted improper stacking of discipline.
June 8, 2019: Sergeant Rhode served as the hearing officer, relied on the January report and Brown’s claimed warning, found Marti guilty of an administrative rules violation, and imposed a 30-day yard-revocation. Marti exhausted administrative remedies and sought habeas relief.
The Court of Appeal held the case was not moot and concluded Rhode’s prior involvement and apparent predetermined belief barred him from acting as hearing officer; it reversed the June 8, 2019 adjudication and ordered the record removed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness / cognizability	Marti: relief is available because administrative adjudication remains in his file and may affect future decisions	Warden: matter is moot because immediate punishments ended and future impact is speculative	Court: not moot; vacatur would provide meaningful relief because adjudication can affect future classification/discipline
Authority to challenge prison regulation violations via habeas	Marti: habeas may vindicate violations of prison regulations	Warden: habeas limited if no atypical hardship or credit impact	Court: habeas may remedy regulatory violations; need not resolve constitutional due process claim
Whether Sergeant Rhode was disqualified as hearing officer	Marti: Rhode reviewed the January report, met with Marti, and thus had a predetermined belief and prior involvement	Warden: Rhode had no direct role in May search; prior finding was vacated and other officers reclassified the new report	Court: Rhode’s review of the January report and other contacts made him unfit under title 15 §3320(h); he should not have adjudicated the case
Appropriate remedy	Marti: vacatur and removal from file	Warden: no relief necessary if moot or harmless	Court: reverse the adjudication and order removal of the record from Marti’s file

Gomez v. Superior Court, 54 Cal.4th 293 (2012) (habeas may vindicate violations of administrative regulations)
People v. Aragon, 11 Cal.App.4th 749 (1992) (courts’ broad remedial powers in habeas; flexibility to correct miscarriages of justice)
In re Brindle, 91 Cal.App.3d 660 (1979) (habeas may secure declarations of rights and address injustices in confinement)
City of San Jose v. International Assn. of Firefighters, Local 230, 178 Cal.App.4th 408 (2009) (mootness doctrine: courts may only afford practical, effectual relief)
Capen v. Shewry, 155 Cal.App.4th 378 (2007) (deference to agency interpretation limited where plain language and facts support judicial reading)