Parks v. Zickfoose, 4:14-cv-00677

Parks, an inmate at USP-Allenwood, filed a pro se habeas corpus petition under 28 U.S.C. §2241 in the Middle District of Pennsylvania.
Respondent is USP-Allenwood Warden Donna Zickefoose; in forma pauperis status granted.
Petitioner does not challenge his federal conviction or sentence; he challenges an August 20, 2011 disciplinary misconduct charge for introduction of narcotics.
Parks contends a visiting sister’s actions led to the charge and he was denied review of videotape evidence; he asserts a due process right to examine the videotape.
DHO sanctioned Parks with 45 days of disciplinary segregation, 6 months commissary loss, 6 months telephone restrictions (suspended), 18 months visitation loss, and a monetary fine; no loss of good conduct time.
Court concludes the sanctions did not affect the length of incarceration and that §2241 relief is not available for these claims; petition dismissed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §2241 relief lies for disciplinary sanctions not affecting confinement length	Parks seeks discharge due to due process and videotape review denial.	Execution challenges under §2241; not petitions for disciplinary measures.	Not available; habeas relief not appropriate.
Whether the petition was properly dismissed under Rule 4 for lack of merit	Petition warrants relief due to due process violations in videotape handling.	Petition fails to show a cognizable habeas claim affecting duration; frivolous as to relief.	Petition properly dismissed.

Fiore v. Lindsay, 336 Fed. Appx. 168 (3d Cir. 2009) (forms of prison discipline other than loss of good time may not be pursued under §2241)
Woodall v. FBI, 432 F.3d 235 (3d Cir. 2005) (habeas review limits when relief does not affect the duration of confinement)
Leamer v. Fauver, 288 F.3d 532 (3d Cir. 2002) (execution-focused habeas review; impact on detention length required)
Linnen v. Armainis, 991 F.2d 1102 (3d Cir. 1993) (habeas relief unavailable for conditions of confinement claims)