Kareem Milhouse v. Warden Lewisburg USP, 700 F. App'x 158

Petitioner Kareem Milhouse challenged a prison disciplinary finding that cost him 68 days of good-conduct time after being charged with possession of a weapon and destroying government property (a damaged mattress).
Officer's written cell-search report and photographs of the homemade knife and damaged mattress were the Hearing Officer’s primary evidence.
Milhouse argued the knife was in a separate mattress on a top bunk and the damaged mattress had another inmate’s name and was given to him already damaged.
The District Court dismissed Milhouse’s § 2241 petition before service; Milhouse appealed.
Milhouse later submitted additional documents via a post-appeal Rule 60(b) motion, which were not part of the district-court record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the disciplinary decision revoking good-conduct time is supported by "some evidence"	Milhouse: insufficient evidence; contraband and damage attributable to other inmate or preexisting condition	Bureau/Hearing Officer: officer report and photos show contraband in shared cell and damaged mattress; institutional procedures support attribution	Affirmed: "some evidence" standard met by cell-search report and photos; shared-cell rule supports possession finding
Whether court of appeals may consider documents filed after district-court decision (Rule 60(b) materials)	Milhouse: requested consideration of post-decision documents attached to Rule 60(b) motion	Respondent: appellate review confined to record before the district court	Court refused to consider post-decision documents; appeal reviewed only district-court record

Superintendent v. Hill, 472 U.S. 445 (some evidence standard for prison disciplinary revocations)
Denny v. Schultz, 708 F.3d 140 (3d Cir.) (contraband found in shared cell can support possession finding)
Fassett v. Delta Kappa Epsilon, 807 F.2d 1150 (3d Cir.) (appellate review limited to district-court record)