Mahan v. State, 94-793
| Decision Date | 31 October 1995 |
| Docket Number | No. 94-793,94-793 |
| Citation | 541 N.W.2d 918 |
| Parties | Russell MAHAN and Bryon Miller, Appellants, v. STATE of Iowa, Appellee. |
| Court | Iowa Court of Appeals |
Philip B. Mears of Mears Law Office, Iowa City, for appellants.
Thomas J. Miller, Attorney General, and Layne M. Lindebak, Assistant Attorney General, appellee.
Heard by DONIELSON, C.J., and HAYDEN and CADY, JJ.
Russell Mahan and Bryon Miller appeal from a district court order denying postconviction relief for sanctions imposed by the Newton Correctional Release Center (CRC). We affirm the district court's order.
Mahan and Miller were inmates at the Newton CRC, a minimum security facility. In October 1992, the two men escaped from the facility. They were later apprehended and criminally prosecuted. After a hearing, the administrative law judge (ALJ) found both men in violation of the CRC's rule against escape and disciplined Mahan and Miller.
In its ruling, the ALJ noted Mahan's whereabouts were unknown until he was arrested in Council Bluffs, Iowa ten days after he escaped, and Miller's whereabouts were unknown until he was arrested in Carrol County, Illinois twenty days after his escape. The Newton CRC guidelines provide inmates can lose up to 2000 days of their good time credits if they escaped from the facility.
In imposing sanctions, the ALJ recognized the serious nature of violation, the CRC recommendation and that the sanctions were within the CRC guidelines. In addition to other disciplinary sanctions, the inmates lost all of their accumulated good time. Mahan had accumulated and lost 1,458 days and Miller 1,835 days as a result of the sanctions.
Miller and Mahan appealed to the warden, but were unsuccessful. The two inmates subsequently filed applications for postconviction relief to the district court alleging an inadequate statement of reasons, arbitrary and capricious sanctions, and a need for additional procedural safeguards due to the severity of the sanctions. At trial, Larry Brimeyer, the Iowa Men's Reformatory hearing officer, testified he revokes 365 days of good time credit for escape as a matter of practice and the Iowa Medical and Classification Center hearing officer generally revokes 90 days of good time for work release escapees. The district court denied the applications noting the ALJ has discretion to assess sanctions in accordance with the severity of the inmate's behavior.
Mahan and Miller appeal claiming the ALJ violated their right to a statement of reasons for the particular punishment imposed. They further contend the withdrawal of good-time credit was arbitrary and capricious in violation of their due process rights. Finally, Mahan and Miller claim they were entitled to additional procedural safeguards to protect their due process rights since the penalty imposed effectively extended their prison sentences in excess of one year.
Postconviction proceedings are law actions, triable to the court, and ordinarily reviewed on error. Kinnersley v. State, 494 N.W.2d 698, 699 (Iowa 1993). Where there is an alleged denial of constitutional rights, we make our own evaluation of the totality of the circumstances in a de novo review. Id.
Miller and Mahan contend the rulings of the ALJ did not contain sufficient statement of reasons for the sanctions imposed. They contend the specificity of the statement of reasons should be dependent upon the severity of the punishment and complexity of the factual circumstances. Mahan and Miller argue the statements given by the committee failed to indicate why the specific penalty was chosen and why other inmates, who escaped from other institutions, receive lower penalties for the exact same violation.
We recognize due process necessitates a written statement of reasons for the imposition of postconviction disciplinary action. Wolff v. McDonnell, 418 U.S. 539, 564-65, 94 S.Ct. 2963, 2979, 41 L.Ed.2d 935, 956 (1974). See LuGrain v. State, 479 N.W.2d 312 (Iowa 1991). An inmate is "not wholly stripped of constitutional protections when he is imprisoned for a crime." Id. at 555, 94 S.Ct. at 2974, 41 L.Ed.2d at 950. In Wolff, the Court acknowledged inmates have a liberty interest in their good-time credit, entitling them to certain procedural safeguards when prison officials purport to deprive such credits. Id. at 557-58, 94 S.Ct. at 2975-76, 41 L.Ed.2d at 951.
The Supreme Court in Wolff also recognized a need for a balance between the institutional needs and objectives of the prison system and the due process provisions of the Constitution. Id. at 556, 94 S.Ct. at 2974, 41 L.Ed.2d at 951. It noted prison disciplinary proceedings "take place in a closed, tightly controlled environment, peopled by those who have chosen to violate the criminal law and who have been lawfully incarcerated for doing so." Id. at 561, 94 S.Ct. at 2977, 41 L.Ed.2d at 954. See also Bruns v. State, 503 N.W.2d 607 (Iowa 1993) (). While due process requires at least a brief written statement by the fact finders as to the evidence presented and the reasons for the disciplinary action, justifications for the precise punishment inflicted are not necessary. Bucklin v. State, 342 N.W.2d 896, 898 (Iowa App.1983). The committee must only "state why the punishment is being inflicted at all; i.e. specific findings of fact indicating petitioner's guilt which in turn points to the need for discipline of some kind." Id.
Throughout its ruling, the committee stated reasons for the sanctions chosen including: the two men had escaped from the facility, Mahan's whereabouts were unknown for ten days, Miller's whereabouts were unknown for twenty days, the violation is of a serious nature, the sanctions were within the CRC guidelines, and CRC officials recommended the sanctions. Moreover, a separate statement of reasons is not necessary to satisfy due process if the factual findings on the alleged violation clearly constitute reasons for the discipline imposed. Davis v. State, 345 N.W.2d 97, 100 (Iowa 1984). We find here the statements given by the ALJ adequately satisfy the due process requirement of a statement of reasons for the punishment imposed.
We also find due process does not require a more particularized and individualized statement when the punishment is more severe. The purposes for the written statement of reasons are to both protect the inmate against collateral consequences based on a misunderstanding of the nature of the original proceeding and to ensure the officials, faced with potential scrutiny by state officials, the public and the courts, will act fairly. Wolff, 418 U.S. at 565, 94 S.Ct. at 2979, 41 L.Ed.2d at 956. Here the written statements provided by the hearing committee serve the purposes set forth in Wolff. The statements reflect the nature of the proceedings--a disciplinary action because the two men escaped. As well, the statements are sufficient for a reviewing body to determine if the officials acted fairly. The Newton facility need only give reasons for its decision to impose sanctions, and need not compare its choice of sanctions with other facilities. We find the statements provided by the disciplinary committee comport with due process.
II. Withdrawal of Good Conduct Credit
Mahan and Miller further allege their due process rights were violated as the deprivation of all accumulated good conduct credit was arbitrary and capricious, given the excessiveness of the penalty, the lack of deliberation on the chosen penalty, inconsistencies between the Newton facilities penalties and other facilities, and the lack of Department of Corrections rulemaking to guide the imposition of the disciplinary penalties.
Iowa Code Chapter 903A provides for the accrual of good conduct time and that "an inmate who intentionally escapes may forfeit all good conduct time accrued and not forfeited prior to escape." Iowa Code § 903A.2(2) (1993). See Picard v. State, 339 N.W.2d 368 (Iowa 1983).
The Newton CRC rules allow the committee to revoke up to 2000 days of good conduct time for a person who escapes from the facility. This information was available to the inmates and designed to discourage escape at the minimum security prison. The sanctions imposed here fall within the statutory and CRC guidelines. The ALJ
may order forfeiture of any or all good conduct time earned ... and has discretion ... to determine the amount of time that should be forfeited based upon the severity of the violation.
Iowa Code § 903A.3 (1993). The ALJ's decision to revoke the good time credit was made in light of the severity of the offense and was not arbitrary or capricious. This decision was well within discretion of the ALJ as the statute and CRC guidelines authorize such a sanction.
Mahan and Miller claim the ALJ's decision was arbitrary and capricious since the ALJ never deliberated on the sanction imposed, and merely followed the CRC's guidelines in revoking up to 2000 days. Again, the ALJ specifically noted its decision took into consideration the seriousness of the violation in assessing its sanctions. See Iowa Code § 903A.3 (1993). As such, the decision evidenced deliberation on the part of the ALJ.
Mahan and Miller further argue the ALJ's actions must be viewed as arbitrary as other institutions across the state revoke fewer days of good conduct time for the same violation. While other institutions may enforce different policies for its determination for the offense of escape, there are no statutory or Department of Corrections guidelines requiring uniformity among the different institutions. See Iowa Code § 903A.3 (1993); Scott v. State, 517 N.W.2d 718, 723 (Iowa...
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