Malcolm Wilson v. Angelita Castaneda
22-3068
| 7th Cir. | Jul 24, 2025Background
- Malcolm Wilson, an Indiana prisoner, was found guilty at a prison disciplinary hearing of battering another inmate, an incident that resulted in the injured inmate being sent to an outside hospital.
- Lieutenant Angelita Castaneda presided over Wilson's disciplinary hearing and, in addition to other penalties, ordered Wilson to pay restitution of up to $100,000 for medical costs.
- Wilson sued under 42 U.S.C. § 1983, arguing the restitution order violated his Fourteenth Amendment due process rights because it was imposed without evidence supporting the amount.
- The district court screened and dismissed Wilson's complaint under 28 U.S.C. § 1915A, finding there was sufficient evidence that the prison incurred some financial loss due to Wilson's actions.
- On appeal, the court reviewed whether due process requires evidence of the precise restitution amount at the time of the disciplinary sanction.
- The Indiana Attorney General participated as amicus curiae due to the peculiar procedural posture (defendant had not been served).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether due process requires evidence supporting the restitution amount at a prison disciplinary hearing | Castaneda ordered excessive restitution with no supporting evidence for the amount, violating due process | Evidence of the battery and resulting hospital visit is sufficient to meet due process; an estimated amount is permissible if later documentation is required by policy | No due process violation; "some evidence" of financial loss (even if not precisely quantified) suffices |
| Whether the specific amount of restitution must be supported by evidence at the time of sanction | Due process requires evidence of the actual or estimated amount before imposing restitution | Policy allows for restitution "up to an estimated amount" if the bill is not yet available; further evidence/documentation can follow | Precise bills are not constitutionally required at time of sanction—evidence of some loss is enough |
| Whether failure to provide exculpatory evidence relating to medical bills violates due process | Denial of access to medical bills is denial of exculpatory evidence | Medical bills are not exculpatory; they do not relate to guilt of battery charge but to amount of loss | No due process violation—no right to bills as exculpatory evidence |
| Whether procedural protections of Wolff v. McDonnell apply to restitution sanctions | Must have Wolff procedures for any deprivation of protected interest, including funds | Same procedures suffice for liberty or property interests; requirements met in Wilson's case | Wolff procedures satisfied; due process met |
Key Cases Cited
- Superintendent, Mass. Corr. Inst., Walpole v. Hill, 472 U.S. 445 (1985) (establishes "some evidence" standard for prison disciplinary sanctions violating liberty or property interests)
- Wolff v. McDonnell, 418 U.S. 539 (1974) (lays out procedural requirements for prison disciplinary hearings)
- Campbell v. Miller, 787 F.2d 217 (7th Cir. 1986) (due process protects prisoners' funds in trust accounts)
- Webb v. Anderson, 224 F.3d 649 (7th Cir. 2000) ("some evidence" standard is minimal, requires only a modicum of evidence in record)
- Arnett v. Webster, 658 F.3d 742 (7th Cir. 2011) (documents attached to complaint are considered part of pleadings)