Terrance Prude v. Anthony Meli, 76 F.4th 648

Background

Terrance Prude, an inmate at Waupun Correctional Institution, received a $10,000 check from a fellow inmate’s attorney purportedly to help retain counsel for Prude’s criminal appeal.
WCI Security Director Anthony Meli seized the check as contraband, opened an investigation, and charged Prude with several disciplinary offenses; Meli refused Prude permission to submit certain evidence for the disciplinary hearing.
Meli allegedly told Prude before the hearing that the funds would be put into the state general fund regardless of the hearing result and offered an undisputed disposition that would permanently seize the $10,000.
Captain Jeremy Westra served as the hearing officer; Prude alleges Westra took cues from Meli, made statements before and after the hearing indicating the outcome was predetermined, and imposed the same punishment Meli had proposed.
The district court dismissed many claims at screening, dismissed Westra as a defendant, and later granted summary judgment for Meli after excluding certain statements as hearsay.
The Seventh Circuit held that the record, viewed in Prude’s favor, plausibly supports a due process violation based on a biased tribunal, reversed summary judgment for Meli in part, reinstated claims against Westra, and remanded for further proceedings.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Prude was denied an impartial decisionmaker	Meli, the investigator, controlled the hearing through Westra, predeciding guilt and punishment	No direct proof of collusion; Westra independently applied policy and was impartial	Reversed summary judgment: facts permit inference that Meli impermissibly influenced the hearing and denied an impartial adjudicator
Whether Prude was denied the right to present evidence at the hearing	Meli forbade Prude from submitting exculpatory evidence (e.g., counsel letter), violating due process	Denial consistent with prison policy; any error was harmless because Prude did not show prejudice	Denial to present evidence rejected at screening but any error was harmless because Prude did not explain how the evidence would have changed the outcome
Whether Meli is entitled to qualified immunity	Right to an unbiased decisionmaker was clearly established; predetermining outcome is unconstitutional	Actions were discretionary and not clearly unlawful under qualified immunity standards	Qualified immunity denied: the right to an impartial adjudicator was clearly established and predetermination is plainly unlawful
Whether district court abused discretion by denying amendment to reinstate Westra and excluding statements as hearsay	Amendment timely and alleges Westra acted as Meli’s puppet; Westra’s statements are admissible to show bias	Amendment untimely and prejudicial; statements are hearsay and inadmissible	Court abused its discretion: amendment and reinstatement of Westra required; many of Westra’s statements are not hearsay when offered to show bias, so they should be considered on remand

Key Cases Cited

Wolff v. McDonnell, 418 U.S. 539 (1974) (establishes procedural due process protections in prison disciplinary hearings)
Whitford v. Boglino, 63 F.3d 527 (7th Cir. 1995) (investigating officer substantially involved in charges cannot serve as adjudicator)
Piggie v. Cotton, 344 F.3d 674 (7th Cir. 2003) (right to call witnesses and present evidence subject to institutional safety; bias presumption high)
Scruggs v. Jordan, 485 F.3d 934 (7th Cir. 2007) (framework for prisoner due process claims involving property and liberty interests)
Cairel v. Alderden, 821 F.3d 823 (7th Cir. 2016) (summary judgment requires admissible evidence; multilayer hearsay considerations)
Mullenix v. Luna, 577 U.S. 7 (2015) (qualified immunity analysis requires context-specific inquiry)
Taylor v. Riojas, 141 S. Ct. 52 (2020) (clearly established rights may be obvious without a case on point)
Mullin v. Temco Mach., Inc., 732 F.3d 772 (7th Cir. 2013) (circumstantial evidence can support inference of improper motive)