Staples v. Maye, 711 F. App'x 866

William Staples, a federal inmate, appealed the district court’s dismissal of his 28 U.S.C. § 2241 petition challenging four DHO disciplinary findings that resulted in loss of Good Conduct Time (GCT).
Two incident reports were previously challenged in an earlier § 2241 action; those claims were dismissed as successive and are not relitigated here.
Incident Report No. 2513440 (Nov. 7, 2013): Staples admitted sending a letter soliciting $550 for commissary; pled guilty at UDC; DHO found him guilty, revoked 14 days GCT and imposed privileges loss; Staples did not receive the DHO report timely and filed a late/regional appeal without the report; Central Office rejected his further appeal for failure to obtain a staff memo explaining untimeliness.
Incident Report No. 2576551 (amended date Apr.–May 2014): charged with assaulting another inmate; DHO found him guilty after hearing where Staples had a staff representative and inmate-written witness statements; Staples filed a regional appeal, resubmitted with a DHO report, which was denied; no record evidence that he completed an appeal to the Central Office.
District court concluded Staples failed to exhaust administrative remedies as to 2513440 and did not establish exhaustion as to 2576551, but in both instances found Staples had received the due-process protections required by Wolff and denied habeas relief. The Tenth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion re: Incident 2513440	Staples says delayed DHO report prevented timely appeal; exhaustion would be futile	BOP: Staples failed to resubmit appeal with staff memo and thus did not pursue available remedies	Affirmed: Staples failed to exhaust (untimely appeal and did not obtain required staff memo)
Due process (Wolff notice & written findings) re: 2513440	Staples argues lack of timely written DHO report violated Wolff	BOP: Staples eventually received the report and had opportunity to defend; any delay did not deprive him of process	Affirmed: No Wolff violation; delay did not cause prejudice that denied due process
Exhaustion re: Incident 2576551	Staples contends he pursued administrative appeals and Central Office received appeal	BOP: Record lacks evidence of a Central Office appeal/response; regional process completed and denied	Held: Staples failed to establish exhaustion (no proof of Central Office appeal)
Due process & sufficiency of evidence re: 2576551	Staples claims procedural defects denied him due process	BOP: Staples received timely notice, could call witnesses, and DHO decision was supported	Held: Affirmed — Wolff protections satisfied and DHO decision supported by "some evidence"

Wolff v. McDonnell, 418 U.S. 539 (1974) (prison disciplinary proceedings require advance written notice, written findings, ability to call witnesses when not unduly hazardous)
Superintendent v. Hill, 472 U.S. 445 (1985) (disciplinary revocation of good-time credits requires "some evidence")
Broomes v. Ashcroft, 358 F.3d 1251 (10th Cir. 2004) (standard of review for § 2241 dismissal is de novo)
Garza v. Davis, 596 F.3d 1198 (10th Cir. 2010) (BOP administrative-exhaustion framework and futility exception)