Donelson v. Pfister, No. 14-3395 (7th Cir. 2016)
Annotate this CaseDonelson, an Illinois prisoner, lost a year of accumulated good time as punishment for two incidents involving the same guard. He claimed that the deprivation occurred without his having an opportunity to call supporting witnesses and to offer supporting evidence and that he was denied access to recordings of the incidents. The state appellate court denied relief without reaching the merits. The court’s reason, not mentioned at any earlier stage of the case, was that the prisoner had not followed the instruction on the paper form for requesting witnesses or evidence to tear off the top portion of the form. Donelson sought a writ of habeas corpus under 28 U.S.C. 2254. The district court ruled against Donelson, partly on the merits and partly on a procedural ground. The Seventh Circuit upheld the partial merits ruling but vacated the procedural ruling. The state court’s “novel ruling carried bureaucratic concerns about paperwork to an unreasonable extreme and does not bar federal consideration of the prisoner’s constitutional claim on the merits.”
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