Kenneth McClure Young, II v. Warren Kann and Jane Doe
926 F.2d 1396 · Court of Appeals for the Third Circuit · 1991
Facts
Kenneth McClure Young, II, a federal prisoner, was charged with threatening his cellmate, partly based on a letter he allegedly wrote. At his disciplinary hearing, the hearing officer, Warren Kann, refused Young's request to produce the letter, relying instead on a guard's oral summary, leading to Young losing good time credit. Young sued, claiming a due process violation, but the district court dismissed his complaint as frivolous.
Issue
Does a prison disciplinary hearing officer violate a prisoner's due process rights by refusing to produce a letter that forms part of the basis for disciplinary charges, especially when the prisoner claims the letter is exculpatory and no security reasons for withholding it are provided?
Holding
Yes, the court held that Young's due process claims were arguably meritorious, finding that the district court erred in dismissing the complaint. The order was vacated, and the case remanded for further proceedings regarding the first disciplinary hearing.
Rule
Under Wolff v. McDonnell, prisoners have a constitutionally protected liberty interest in good time credit, entitling them to due process at disciplinary hearings, including the right to present documentary evidence in their defense. This right is limited only by legitimate institutional safety or correctional goals, and arbitrary denial of such evidence, without valid security reasons, violates due process.
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