Santiago-Lugo v. Warden, No. 13-14384 (11th Cir. 2015)
Annotate this CaseA cell phone was found during a random search in the Federal Correctional Complex at Coleman Medium Prison in Florida. An examination of the phone’s call history showed that the son of inmate Israel Santiago-Lugo had called that phone the day before it was found. Santiago-Lugo was charged in a prison incident report with having violated the rule against possession of a cell phone. After a hearing he was instead found to have violated the rule against conduct that disrupts or interferes with the orderly running of the institution. As a result, he lost good time credits and suffered other sanctions. Santiago-Lugo filed a 28 U.S.C. 2241 petition claiming that his procedural due process rights had been violated in the disciplinary proceeding. The district court ruled that it lacked subject matter jurisdiction because he had failed to exhaust his administrative remedies. The court alternatively ruled that his due process claim failed on the merits. Santiago-Lugo appealed to the Eleventh Circuit. The Warden conceded that Santiago-Lugo exhausted his administrative remedies, so the district court did have jurisdiction to hear his appeal; however the Court found no violation of due process rights when good time credits and other sanctions were imposed.
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