Walton v. Fikes
- Katherine Menendez
- 0:21-cv-01269
- U.S. District Court · District of Minnesota
- 2
In Walton v. Fikes, Judge Menendez denied Walton’s prison-discipline habeas petition, finding no due-process violation, and dismissed the action with prejudice.
Reginald Anthony Walton, whose petition challenging the loss of 82 days of good-conduct time was denied and whose action was dismissed with prejudice; the defendants prevailed.
What happened
In Walton v. Fikes, Reginald Anthony Walton challenged disciplinary sanctions imposed after prison officials found him possessing cellular telephones, alcohol, and drugs. A disciplinary hearing officer took away 82 days of good-conduct time, and Walton argued that administering his sentence this way violated his constitutional rights.
Magistrate Judge Elizabeth Cowan Wright recommended denying Walton’s petition because he had not shown a violation of his due-process rights. She also recommended dismissing the action with prejudice. No objections were filed, so the district court reviewed the recommendation for clear error.
Judge Katherine M. Menendez accepted the recommendation, denied Walton’s petition under 28 U.S.C. § 2241, and dismissed the action with prejudice. The court found that the magistrate judge had committed no error.
The detailed version
- Walton v. Fikes · No. 0:21-cv-01269
- Katherine Menendez
- May 24, 2022
Background
Reginald Anthony Walton filed a petition under 28 U.S.C. § 2241, a federal procedure that allows a person in custody to challenge the manner in which a sentence is being carried out. Walton challenged disciplinary sanctions connected to his possession of cellular telephones while incarcerated at the Federal Correctional Institution in Fort Dix, New Jersey. Prison officials found that he violated rules prohibiting possession of cellular phones, alcohol, and drugs. A disciplinary hearing officer sanctioned him by disallowing 82 days of good-conduct time.
Walton claimed that the administration of his sentence violated his constitutional rights. The opinion states that the magistrate judge’s Report and Recommendation addressed his claims and recommended denying the petition because Walton had not demonstrated a violation of his due-process rights. The recommendation also called for the action to be dismissed with prejudice, meaning the action was barred from being brought again in the same form.
Review and Ruling
No objections were filed to the Report and Recommendation. The district court therefore reviewed it for clear error rather than conducting the de novo review that applies to portions challenged by specific objections. Judge Menendez stated that her review of the recommendation and the record disclosed no error, clear or otherwise.
The court ordered that the Report and Recommendation be accepted, the § 2241 petition be denied, and the action be dismissed with prejudice. Judgment was ordered to be entered accordingly.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.