Chambers v. Ciolli, No. 21-1485 (7th Cir. 2021)
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Chambers appealed the denial of two petitions for habeas corpus, asserting that he was denied due process in prison disciplinary hearings. Chambers lost good-time credit for one incident of refusing a prison guard’s instructions to provide a urine sample, disobeying a staff member’s order, and acting with insolence towards the staff member and another incident of interfering with a security device (he had activated a cell alarm by forcibly kicking his cell door). The hearing officers discounted Chambers’s claim that the guard never asked for a sample, noting video evidence that the guard was carrying a sample bottle and found Chambers guilty based on his undisputed statement to the guard that he was not in distress or having a medical emergency when he kicked his cell door.
The Seventh Circuit affirmed. The disciplinary determinations were supported by sufficient evidence. Chambers had no due-process right to call witnesses whose testimony would be repetitive and irrelevant. The record lacked any evidence of bias and the initial reviews of Chambers’s cases by a one-member Unit Disciplinary Committee complied with BOP rules. Federal courts must affirm prison disciplinary decisions if they are supported by “some evidence,” and the incident reports cleared that low bar. “Chambers, a frequent litigant, is warned that he risks monetary sanctions if he continues to repeat in future cases these arguments that we have found to be frivolous.”
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