James v. Alaska Dept. of Corrections
Annotate this CaseAfter a disciplinary hearing, a hearing officer found Alaska prison inmate Joseph James guilty of the “low-moderate” infraction of “threatening another person with future bodily harm” at Red Rocks Correctional Center in Arizona. The determination was based entirely on an incident report written by a prison staff member who had not witnessed the incident. Instead, the report’s author provided a hearsay account of a conversation between James and another staff member. After exhausting his administrative remedies, James filed an appeal to the superior court. James argued that basing the finding of guilt solely on the hearsay written account constituted a violation of his due process rights. James also maintained that the failure to audio-record the disciplinary hearing violated due process. The superior court affirmed the disciplinary determination. Because the Supreme Court concluded that James’s due process right to confront and cross-examine adverse witnesses was violated during the disciplinary proceedings and that he was prejudiced by the failure to audio-record the disciplinary hearing, the Court vacated the disciplinary determination and remanded the case for a new hearing.
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