William Lewis v. Warden Canaan USP
664 F. App'x 153
| 3rd Cir. | 2016Background
- On Nov. 29, 2012, inmate William Solomon Lewis refused a recreation staff member's order to remove his hat and used racial epithets; staff reported he threatened the employee.
- Lewis received advance written notice charging Code 203 (threatening bodily harm) and Code 307 (refusing an order).
- At the DHO hearing Lewis admitted refusing the order and using a slur but denied making threats; requested witnesses submitted statements saying they did not observe the incident; video was inconclusive.
- The DHO found Lewis guilty of both charges and imposed loss of 27 days' good conduct time, 30 days' disciplinary segregation, plus other sanctions.
- Lewis exhausted administrative remedies and filed a § 2241 habeas petition arguing due process violations, DHO bias, and that Code 203 is unconstitutionally vague.
- The District Court denied relief; the Third Circuit summarily affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Were due process protections at the disciplinary hearing sufficient (some evidence standard)? | Lewis: DHO lacked sufficient evidence to support revocation of good-time credits. | BOP: Incident report, staff account, and Lewis’s partial admission satisfy the "some evidence" standard. | Held: Satisfied — DHO decision supported by some evidence. |
| Did the DHO have to recuse for bias? | Lewis: DHO was biased and should have recused. | BOP: Allegation of general bias insufficient; no direct personal involvement shown. | Held: Denied — general bias claim insufficient to show disqualifying involvement. |
| Is Code 203 unconstitutionally vague on its face? | Lewis: Code 203 gives excessive discretion and forecloses staff-misconduct defense. | BOP: Regulation gives fair notice and limits discretion; 28 C.F.R. § 541.8(f) requires decisions be fact-based and weigh evidence. | Held: Denied — Code 203 not unconstitutionally vague. |
| Does loss of commissary privileges (Code 307) trigger due process protections? | (Implicit) Lewis: Challenged discipline generally. | BOP: Short commissary loss is not an atypical, significant hardship triggering due process. | Held: Not a protected liberty interest here — sanctions for Code 307 did not trigger due process for loss of good-time credits. |
Key Cases Cited
- Edwards v. Balisok, 520 U.S. 641 (establishes § 2241 route for challenges implicating good-time credits)
- Wolff v. McDonnell, 418 U.S. 539 (procedural due process protections required in prison disciplinary hearings)
- Superintendent v. Hill, 472 U.S. 445 ("some evidence" standard for prison disciplinary findings)
- Denny v. Schultz, 708 F.3d 140 (standard of review for § 2241 habeas in Third Circuit)
- Meyers v. Alldredge, 492 F.2d 296 (recusal/ bias requirements for prison disciplinary decisionmakers)
- Johnson v. United States, 576 U.S. 591 (void-for-vagueness framework)