William Lewis v. Warden Canaan USP, 683 F. App'x 113

William Lewis, a federal inmate, refused a PPD tuberculosis skin test and requested a chest x-ray instead; staff charged him with a Code 227 refusal.
Lewis claimed prior blistering/swelling after a PPD and said that justified a chest x-ray; he produced no documentary proof of a prior severe reaction.
At the disciplinary hearing, staff witnesses disputed Lewis’s claim and records showed a prior PPD in 2012 with no documented allergy; a prior incident report quoted Lewis as saying he had no severe reactions.
The Disciplinary Hearing Officer found Lewis guilty, revoked 27 days of good-conduct time, and imposed other sanctions.
Lewis filed a § 2241 habeas petition seeking restoration of good-conduct time, arguing due-process violations and that administrative-exhaustion should be excused because his appeals were not answered.
The District Court denied relief on the merits, finding Lewis received required process and that the Hearing Officer’s decision was supported by "some evidence." The Third Circuit summarily affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lewis was denied due process in the disciplinary proceeding	Lewis: hearing lacked fair adjudication; he credibly reported a severe allergic reaction and was entitled to substitute chest x-ray	BOP: Lewis received required Wolff protections; hearing testimony and records undermine his allergy claim	Court: Due process satisfied; Lewis had notice, opportunity to be heard, and staff representation; credibility issues properly resolved
Whether "some evidence" supported the finding of guilt	Lewis: self-reported severe reaction should suffice under P.S. 6190.04 to excuse PPD	BOP: records and staff statements provided evidence that Lewis had no documented severe reaction and that his self-report was not credible	Court: "Some evidence" standard met; prior records and incident report supported finding of unjustified refusal
Whether administrative-exhaustion requirement was excused	Lewis: regional appeal unanswered; exhaustion should be waived under Brown v. Croak when officials thwart appeals	BOP: Lewis failed to complete administrative process; exhaustion or cause-and-prejudice rule applies per Moscato	Court: Did not resolve exhaustion dispute; denied petition on merits instead
Standard of review on appeal	N/A (procedural)	N/A	Court: Reviews legal conclusions de novo and factual findings for clear error; no substantial question warranted reversing the district court

Brown v. Croak, 312 F.3d 109 (3d Cir.) (administrative remedies deemed unavailable when prison officials thwart exhaustion)
Moscato v. Federal Bureau of Prisons, 98 F.3d 757 (3d Cir.) (procedural default and exhaustion principles for prisoner claims)
Burkey v. Marberry, 556 F.3d 142 (3d Cir.) (COA not required to appeal denial of § 2241)
Woodall v. Federal Bureau of Prisons, 432 F.3d 235 (3d Cir.) (execution-of-sentence challenges brought under § 2241)
Wolff v. McDonnell, 418 U.S. 539 (U.S.) (due process protections required at prison disciplinary hearings)
Superintendent, Mass. Corr. Inst. v. Hill, 472 U.S. 445 (U.S.) (disciplinary findings must be supported by "some evidence")
Rios v. Wiley, 201 F.3d 257 (3d Cir.) (standard of review: legal conclusions de novo, factual findings for clear error)