Spooner v. State
| Decision Date | 22 May 1984 |
| Docket Number | 5 Div. 857 |
| Citation | 451 So.2d 429 |
| Parties | Loren SPOONER v. STATE. |
| Court | Alabama Court of Criminal Appeals |
Robert B. Reneau of Reneau & Reneau, Wetumpka, for appellant.
Charles A. Graddick, Atty. Gen., and Louis C. Colley, Asst. Atty. Gen., for appellee.
Spooner appeals the summary dismissal of his pro se petition for writ of habeas corpus challenging the constitutionality of a disciplinary proceeding which resulted in the loss of four months' good time. In his petition, Spooner specifically asserted that the institutional officers took disciplinary action against him without providing him with a constitutionally sufficient statement of the reasons for their actions and the evidence upon which they relied. Spooner's petition was dismissed upon the State's motion. Attached to this motion was a copy of the Disciplinary Report 1 and an unsworn statement of the arresting officer. The "Committee findings & reasons" recited in the Disciplinary Report are as follows:
In Wolff v. McDonnell, 418 U.S. 539, 94 S.Ct. 2963, 41 L.Ed.2d 935 (1974), the Supreme Court held that due process requires that an inmate involved in a prison disciplinary proceeding must be provided with a written statement by the factfinders as to the evidence relied upon and the reasons for the disciplinary action taken. Id. at 565, 94 S.Ct. at 2979. The written statement protects the inmate from possible collateral consequences based on a misunderstanding of the nature of the original proceeding and from arbitrary action by prison officials and enables him to "propound his own cause" subsequent to the hearing. Id. at 565, 94 S.Ct. at 2979.
This court has observed this Wolff standard in determining statements similar to the instant one to fall short of the inmate's minimal procedural due process rights. In Barker v. State, 437 So.2d 1375 (Ala.Crim.App.1983), we found the following statement by a disciplinary board to be in violation of Wolff: In Barnhill v. State, 439 So.2d 822 (Ala.Crim.App.1983), the following statement was likewise deemed insufficient: Finally, in Martin v. State, 449 So.2d 801 (Ala.Crim.App.1984), this court adjudged the...
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Owens v. State, 7 Div. 781
...which does not meet the due process requirements of Wolff v. McDonnell, and which we have accordingly condemned. Spooner v. State, 451 So.2d 429 (Ala.Cr.App.1984); Barker v. State. The record before us supports appellant's allegation that the board did not make a written statement setting f......
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Rice v. State, 5 Div. 885
...Barnhill v. State, 439 So.2d 822 (Ala.Crim.App.1983); Martin v. State, 449 So.2d 801 (Ala.Crim.App.1984); Spooner v. State, 451 So.2d 429 (Ala.Crim.App.1984). The State contends that the written statement contained in the disciplinary report together with the written record of the testimony......
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Jackson v. State
... ... Thus, the constitutional requirements of Wolff were not met. Further, this court, again speaking through Judge Patterson, in Spooner v. State, 451 So.2d 429 (Ala.Cr.App.1984), stated: ... "In Wolff v. McDonnell, 418 U.S. 539, 94 S.Ct. 2963, 41 L.Ed.2d 935 (1974), the Supreme Court held that due process requires that an inmate involved in a prison disciplinary proceeding must be provided with a written statement by the ... ...
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Heidelburg v. State
...him to "propound his own cause" subsequent to the hearing. Wolff v. McDonnell, 418 U.S. at 565, 94 S.Ct. at 2979; Spooner v. State, 451 So.2d 429, 430 (Ala.Cr.App.1984). To meet the due process standard, the disciplinary board's decision must neither be arbitrary nor capricious, and must be......