Rhea v. Butler, 6:16-cv-00201

On Aug. 29–30, 2015, inmate Gregory Rhea twice touched/poked chaplain T. Jahr in the abdomen after the chaplain warned him an incident report would be written.
Chaplain Jahr escorted Rhea to a lieutenant and filed an incident report charging Code 299 conduct (disruption/assault-like).
A disciplinary hearing (Sept. 11, 2015) found Rhea guilty of Interfering with a Staff Member in the Performance of Duties (Most Like Code 224) and imposed sanctions including loss of 27 days’ good conduct time.
Rhea exhausted administrative appeals challenging the finding and sanctions, arguing the contact was a harmless “pat,” did not interfere with duties, and objecting to the report’s wording.
Rhea filed a pro se § 2241 habeas petition claiming the disciplinary conviction lacked the constitutionally required “some evidence.”
The district court reviewed the record de novo for the Hill some-evidence standard and denied habeas relief, concluding sufficient evidence supported the DHO’s finding that the contact interfered with the chaplain’s duties.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether disciplinary finding was supported by "some evidence" to revoke good-time credits	Rhea: touching was a harmless "pat," did not interfere with chaplain's duties	Respondent: chaplain spent time addressing the conduct and had to escort Rhea and file report; those acts show interference	Held: Some evidence existed; DHO reasonably concluded the twice-occurring contact interfered with duties, so Hill standard met
Whether report wording/charge labeling violated due process or altered analysis	Rhea: report used inflammatory term "jab" and mischaracterized offense; alleged conviction should not stand	Respondent: wording and precise assault label irrelevant; conviction was for interfering with staff (Code 298/most like 224) and focuses on interference, not severity	Held: Wording immaterial to constitutional inquiry; the interference-focused charge was supported by evidence

Erickson v. Pardus, 551 U.S. 89 (pro se complaints are held to less stringent standards)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading standards and construing allegations)
Wolff v. McDonnell, 418 U.S. 539 (due process protections in prison disciplinary proceedings)
Superintendent v. Hill, 472 U.S. 445 (disciplinary findings revoking good time must be supported by "some evidence")
Selby v. Caruso, 734 F.3d 554 (6th Cir. application of Hill standard)
Higgs v. Bland, 888 F.2d 443 (review under some-evidence standard does not permit reweighing evidence)
Koffman v. Garnett, 574 S.E.2d 258 (S.C. Ct. App.) (even a pat can be offensive contact supporting assault theory)