John Melnik v. James Dzurenda, 14 F.4th 981

John Melnik, a Nevada prisoner, was charged with smuggling drugs after two envelopes addressed to him containing methamphetamine in hidden compartments were intercepted.
Melnik repeatedly requested to inspect the envelopes or receive copies to prepare his defense; prison officials denied or ignored those requests.
At the disciplinary hearing, photos and descriptions of the envelopes were presented as the sole evidence; Melnik testified he was framed and was found guilty.
He received two consecutive 18‑month terms of disciplinary segregation (36 months total), served 10 months before suspension, and alleges parole was delayed two years as a result.
Melnik sued under 42 U.S.C. § 1983 for violation of Fourteenth Amendment procedural due process; the district court found a due‑process violation, denied defendants qualified immunity, and granted liability summary judgment; defendants appealed only the denial of qualified immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a prisoner has a constitutional right to access documentary evidence (envelopes or copies) used in a prison disciplinary hearing	Melnik: Wolff requires ability to present documentary evidence; that entails access to prepare and compile evidence (copies or inspection)	Defendants: Prisoners' rights are limited by penological concerns; access may be denied for confidentiality or security reasons	Held: Yes. Under Wolff and related precedents, a prisoner has a qualified due‑process right to access evidence to prepare a defense absent legitimate penological justification
Whether the right was "clearly established" such that defendants are not entitled to qualified immunity	Melnik: The right to access evidence was clearly established when he requested copies; defendants were on notice	Defendants: The right was not clearly established here because the envelopes were stored in an evidentiary vault and labeled confidential under NDOC rules; logistical/administrative factors mitigate notice	Held: No qualified immunity. The court concluded the right was clearly established as of the time of denial and the vault/confidentiality argument did not supply a legitimate penological justification to withhold copies

Wolff v. McDonnell, 418 U.S. 539 (1974) (prisoners have right to call witnesses and present documentary evidence in disciplinary proceedings if not unduly hazardous to safety or correctional goals)
Ponte v. Real, 471 U.S. 491 (1985) (prison officials must explain why a prisoner was denied the right to call witnesses or present evidence)
Zimmerlee v. Keeney, 831 F.2d 183 (9th Cir. 1987) (reasons for denying witness or documentary requests may be provided at hearing or later; courts must be able to review denials)
Piggie v. Cotton, 344 F.3d 674 (7th Cir. 2003) (labeling evidence "confidential" without logical foundation is not a valid security justification for withholding it)
Bostic v. Carlson, 884 F.2d 1267 (9th Cir. 1989) (administrative efficiency is not an adequate justification to deny inmates the right to call important witnesses or present evidence)
Lennear v. Wilson, 937 F.3d 257 (4th Cir. 2019) (recognizing a prisoner’s qualified right to access evidence and to compel official review)
Brown v. Oregon Dept. of Corrections, 751 F.3d 983 (9th Cir. 2014) (administrative segregation implicates a protected liberty interest)
Young v. Lynch, 846 F.2d 960 (4th Cir. 1988) (earlier Fourth Circuit decision expressing doubt that Wolff requires production of physical evidence)