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, brought suit against Warren Kann, a disciplinary hearing officer, claiming Kann violated his due process rights by refusing to produce a letter in which Young allegedly threatened his cellmate, even though the letter formed part of the basis for the disciplinary charges, resulting in Young losing substantial good time credit. The district court dismissed the complaint as legally frivolous.
Issue
Does a prisoner have a due process right to the production of documentary evidence at a prison disciplinary hearing when that evidence forms part of the basis for the disciplinary charges?
Holding
Yes, the court held that Young's due process claims are arguably meritorious and that the district court erred in dismissing the complaint, vacating the order and remanding the case.
Rule
A prisoner facing disciplinary charges must have an opportunity to marshal the facts and prepare a defense, including the right to present documentary evidence in his defense when it will not be unduly hazardous to institutional safety or correctional goals; this right is limited only by the demands of prisoner safety and institutional order, as determined by the sound discretion of the prison authorities, but the denial of such evidence cannot be arbitrary.
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