This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A prisoner was charged with multiple prison violations, including fraud (Category A offense), willfully refusing to obey a lawful order (Category B offense), and improper use of equipment (Category C offense). The Category A offense was dismissed, and the Category B offense was elevated to a major level offense due to repeated behavior, resulting in the forfeiture of 90 days of good-time credits and 25 days of disciplinary segregation. The prisoner alleged he was not notified of the potential elevation of the Category B offense to a major level offense before the disciplinary hearing (paras 4-7, 20).
Procedural History
- District Court: The habeas corpus petition was dismissed without a hearing. The court found that disciplinary procedures were followed and judicial review was not warranted unless there was clear abuse or capricious action by prison officials (paras 1, 8, 11).
Parties' Submissions
- Petitioner: Argued that the district court erred in dismissing the petition without a hearing, as there was no evidence supporting compliance with disciplinary procedures. Claimed he was wrongfully deprived of good-time credits due to lack of notice about the elevation of the Category B offense and the use of an improper basis for the elevation (paras 2, 10).
- Respondent: Asserted that the dismissal was proper because the facts showed the petitioner was not entitled to relief as a matter of law. Argued that the petitioner had sufficient notice of the potential elevation of the Category B offense (paras 10, 18).
Legal Issues
- Was the petitioner wrongfully deprived of good-time credits due to a lack of notice about the elevation of the Category B offense to a major level offense?
- Was the petitioner wrongfully deprived of good-time credits due to the use of an improper basis for the elevation of the Category B offense?
- Did the district court err in dismissing the habeas corpus petition without holding an evidentiary hearing?
Disposition
- The Supreme Court of New Mexico reversed the district court's dismissal and remanded the case for review of the petition and an evidentiary hearing on the notice issue (paras 3, 23-24).
Reasons
Per Petra Jimenez Maes, Chief Justice (Minzner and Serna JJ. concurring):
The district court erred in dismissing the habeas corpus petition without review or an evidentiary hearing. The petitioner raised sufficient factual allegations to establish a prima facie case that his good-time credits were wrongfully deprived due to lack of notice and an improper basis for the elevation of the Category B offense. The court emphasized that the deprivation of good-time credits implicates a protected liberty interest under the Due Process Clause, requiring compliance with statutory, administrative, and due process procedures (paras 12-14, 21-22).
The petitioner was entitled to advance written notice of the charges and the potential elevation of the Category B offense to a major level offense. The record indicated that prison officials failed to provide such notice, violating both due process principles and prison regulations. The district court was required to hold an evidentiary hearing to determine the validity of the petitioner's allegations regarding notice. The court also directed the district court to review whether an improper basis was used to elevate the offense and hold a hearing if warranted (paras 15-20, 23).