William Rand v. Rachel Chapa, 18-40972

William N. Rand, a federal prisoner, was disciplined for possessing an unauthorized SD chip found during a search of his locker and lost 41 days of good-time credits.
Disciplinary Hearing Officer (DHO) Aundra Thomas presided; the conviction relied on an incident report and photographs showing the chip.
Rand filed a pro se § 2241 petition challenging (1) DHO impartiality, (2) whether the chip was a "hazardous tool," (3) whether he possessed the chip, and (4) denial of opportunity to investigate and present exculpatory evidence.
The district court denied relief; the government argued the record contained "some evidence" supporting the conviction and that any procedural error caused no prejudice.
On appeal Rand abandoned other claims; the Fifth Circuit reviewed factual findings for clear error and legal conclusions de novo and affirmed the denial of § 2241 relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
DHO impartiality	Thomas was biased against Rand	Thomas was not involved in the underlying incident and thus not biased	No bias; DHO impartial because she had no involvement in the incident
Whether chip was a "hazardous tool"	Chip did not meet hazardous-tool definition under 28 C.F.R. § 541.3	Incident report, photos, Thomas's declaration, and BOP policy supported hazardous-tool finding	Affirmed; "some evidence" supports hazardous-tool classification
Possession of the chip	Rand did not possess the chip	Constructive possession established by chip in Rand's locker and BOP policy holding inmates responsible for contraband	Affirmed; incident report and photos supply "some evidence" of constructive possession
Denial of opportunity to investigate/present evidence (due process)	Denial of witnesses/evidence violated Wolff rights and prejudiced outcome	Even if procedure violated, Rand cannot show prejudice; outcome would not change	Denial not remediable; Rand failed to show prejudice, so no § 2241 relief

Superintendent, Mass. Corr. Inst. v. Hill, 472 U.S. 445 (U.S. 1985) ("some evidence" standard for prison disciplinary findings)
Teague v. Quarterman, 482 F.3d 769 (5th Cir. 2007) (de novo review of legal question whether record contains some evidence)
Morgan v. Dretke, 433 F.3d 455 (5th Cir. 2005) (single report or witness can satisfy some-evidence standard)
Wolff v. McDonnell, 418 U.S. 539 (U.S. 1974) (due-process protections in prison disciplinary hearings)
Simpson v. Ortiz, 995 F.2d 606 (5th Cir. 1993) (prejudice required to obtain relief for Wolff violations)
Brinkmann v. Dallas Cty. Deputy Sheriff Abner, 813 F.2d 744 (5th Cir. 1987) (pro se brief abandonment and standards on procedural claims)
Adams v. Gunnell, 729 F.2d 362 (5th Cir. 1984) (bias/impartiality analysis for hearing officers)
Henson v. U.S. Bureau of Prisons, 213 F.3d 897 (5th Cir. 2000) (standard of review for factual findings)
Ross v. Estelle, 694 F.2d 1008 (5th Cir. 1983) (conclusory assertions of prejudice are insufficient)
Yohey v. Collins, 985 F.2d 222 (5th Cir. 1993) (liberal construction of pro se briefs and effect of abandonment)