Isenberg v. Pennsylvania Board of Parole, 4:24-cv-01662

Petitioner Ronald K. Isenberg, Jr. is serving an 18- to 40-year sentence for criminal homicide, with parole eligibility beginning April 2015 and maximum release in 2037.
The Pennsylvania Board of Parole denied Isenberg's parole request in September 2024, citing lack of remorse, failure to accept responsibility, minimizing the offense, and a negative prosecutor recommendation.
Isenberg filed a pro se petition for a writ of habeas corpus under 28 U.S.C. § 2254, arguing the parole denial violated his substantive due process rights under the Fourteenth Amendment.
Respondent timely opposed the petition after being served; Isenberg did not file a reply.
The petition was resolved on the merits without analyzing exhaustion of state remedies, as allowed under federal law.
The district court denied Isenberg’s petition and declined to issue a certificate of appealability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether parole denial violated Isenberg's substantive due process rights	Parole Board’s reasons were arbitrary and ignored rehabilitation	Parole Board gave valid, non-arbitrary reasons	Denial was not arbitrary or conscience-shocking; petition denied

Newman v. Beard, 617 F.3d 775 (3d Cir. 2010) (explains substantive due process protections for parole decisions)
Holmes v. Christie, 14 F.4th 250 (3d Cir. 2021) (parole board actions only violate due process if conscience-shocking)
Coady v. Vaughn, 251 F.3d 480 (3d Cir. 2001) (standard for federal habeas review of parole decisions)
Hunterson v. DiSabato, 308 F.3d 236 (3d Cir. 2002) (federal courts should not second-guess parole determinations)
Block v. Potter, 631 F.2d 233 (3d Cir. 1980) (use of arbitrary criteria by parole board may violate substantive due process)