Donelson v. Pfister

Federal 7th Circuit Court
Criminal Court
Due Process
Citation
Case Number: 
No. 14-3395
Decision Date: 
January 28, 2016
Federal District: 
C.D. Ill.
Holding: 
Vacated and remanded

Dist. Ct. erred in denying plaintiff-prisoner’s habeas petition challenging prison committee’s forfeiture of plaintiff’s good-time credits based on two disciplinary reports that accused plaintiff of misconduct within prison, where: (1) plaintiff asserted that prison committee made its ruling without considering his proposed list of witnesses and exhibits; and (2) state court found that committee was not required to consider such proposed witnesses/exhibits where, although plaintiff had submitted said list on prison-supplied form, plaintiff had failed to tear said list from such form as he was instructed to do. Committee could not ignore plaintiff’s list where plaintiff had essentially communicated his request for said witnesses/exhibits, and state court could not find that plaintiff procedurally defaulted his challenge to loss of good-time credits, where his failure to tear off list from submitted form was not adequate state-law ground for refusing his request to call witnesses and submit exhibits on said list. Moreover, list of witnesses/exhibits had potential to undermine committee’s decision to find plaintiff guilty of misconduct.