Wallace Dean-Mitchell v. Warden, 837 F.3d 1107

Background

Dean-Mitchell, a D.C. Code offender serving 35 years-to-life, lost 27 days of statutory D.C. good‑time credit after a 2006 disciplinary DHO proceeding (Incident Report 1507668).
He filed a § 2241 habeas petition challenging ten disciplinary actions; on appeal he contested only the Incident Report dismissal.
He alleged he never received the Incident Report or the DHO report (written statement of findings), so his Wolff due‑process rights (advance written notice and written reasons) were violated.
The Warden produced copies of the Incident Report and DHO report and stated he must have had them to file administrative appeals; the district court converted the response into a summary‑judgment motion.
The district court initially ordered an evidentiary hearing but later granted summary judgment for the Warden, relying on a declaration and concluding there was “some evidence” that Dean‑Mitchell received the reports.
The Eleventh Circuit reversed, finding genuine disputes of material fact about receipt of the reports and that the district court incorrectly applied the “some evidence” standard instead of resolving the summary‑judgment factual disputes or holding an evidentiary hearing.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dean‑Mitchell received constitutionally required advance written notice (Incident Report).	He asserts he never received the Incident Report and lacked factual notice to defend.	Warden says record copies show delivery (date/time/initials) and administrative appeals indicate he had the documents.	Genuine factual dispute exists; summary judgment improper — district court must resolve via hearing or deny summary judgment.
Whether Dean‑Mitchell received the DHO report (written statement of reasons).	He contends the DHO report was never provided and was missing from his file in 2007 and 2010.	Warden produced a DHO report stating a copy was given to the inmate and argued appeals required attaching the report.	Genuine dispute over receipt; Warden’s regulation‑based premise was incorrect; summary judgment was erroneous.
Whether the district court could grant summary judgment based on “some evidence” (Superintendent v. Hill).	Dean‑Mitchell argues Hill’s “some evidence” test is irrelevant because he challenges procedural notice, not sufficiency of evidence.	Warden relied on court’s citing of “some evidence” to support finding he received the reports.	Court held Hill is inapplicable to procedural-notice claims under Wolff; district court misapplied the standard.
Whether a COA was required and should be granted.	Implicitly sought to appeal without a prior COA; merits are debatable.	Warden questioned jurisdiction absent a COA because the case originated in D.C.	Court granted a COA, finding the district court applied the wrong legal standard and the constitutional claim is debatable.

Key Cases Cited

Wolff v. McDonnell, 418 U.S. 539 (1974) (establishes minimum due‑process protections in prison disciplinary proceedings, including notice and written statement of reasons)
Superintendent, Mass. Corr. Inst., Walpole v. Hill, 472 U.S. 445 (1985) (evidence supporting revocation of good‑time credits must be supported by "some evidence")
Edwards v. Balisok, 520 U.S. 641 (1997) (clarifies Hill does not replace Wolff; Hill is irrelevant when claim attacks procedural defects rather than sufficiency of evidence)
Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary judgment standard: genuine dispute as to material fact precludes judgment)