Walker v. State, Dept. of Corrections, 421 P.3d 74

Scott Walker, an inmate at Goose Creek Correctional Center, was paid for an Orientation Assistant job he stopped performing; DOC concluded he was overpaid $633.50.
DOC charged Walker with stealing/damaging government property and lying/providing a false statement to staff; a hearing officer found him guilty of making a false statement and ordered restitution of $316.
Walker had requested three witnesses (two officers and an inmate) for the disciplinary hearing; the hearing officer denied or failed to call them and did not provide the required written reasons for declining.
Walker appealed administratively to the superintendent (arguing only lack of evidence), then to superior court (raising for the first time that DOC denied his right to call witnesses and that restitution was unauthorized).
The superior court affirmed, holding Walker waived issues not raised administratively; the Alaska Supreme Court granted review on due-process/wavier and witness-right issues.
The Supreme Court reversed, holding Walker did not forfeit his due-process claim and that denial of his requested witnesses was a prejudicial violation requiring a new hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prisoner forfeits constitutional claims not raised to DOC superintendent	Walker: constitutional due-process claim (denial of witnesses) preserved; should be reviewable despite not being raised to superintendent	State: James requires issue exhaustion—claims not raised administratively are waived	Court: No automatic forfeiture; overrules James to extent inconsistent; constitutional claims need not be raised administratively to avoid waiver in these proceedings
Whether DOC violated due process by refusing to call witnesses and whether that error was harmless	Walker: hearing officer denied requested witnesses and failed to state reasons; witnesses could have rebutted DOC’s factual basis	State: hearing officer has discretion to limit witnesses; decision supported by some evidence	Court: Prisoner has constitutional right to call witnesses in major disciplinary hearings; failure to call witnesses and to file required reasons violated due process and was prejudicial; reversal and remand for new hearing

James v. State, Dep’t of Corr., 260 P.3d 1046 (Alaska 2011) (previously applied issue-exhaustion to prison disciplinary appeals)
Abruska v. Dep’t of Corr., State, 902 P.2d 319 (Alaska 1995) (inmate entitled to call witnesses in major disciplinary proceedings)
Sims v. Apfel, 530 U.S. 103 (2000) (issue-exhaustion requirements depend on context; not always appropriate)
McKart v. United States, 395 U.S. 185 (1969) (exhaustion purposes require context-specific analysis)
United States v. L.A. Tucker Truck Lines, Inc., 344 U.S. 33 (1952) (courts generally decline to upset administrative rulings not challenged at the appropriate administrative stage)