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Name: In re Williams
Case #: D066887
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 10/23/2015
Summary

Habeas petition challenging prison’s lost-property administrative appeal process dismissed because inmate failed to show that the process implicates any liberty interest protected by the due process clause. When Williams was transferred from one prison (CMF) to another (Donovan), his television was confiscated as contraband. He filed a lost-property appeal, but it was rejected on the basis that he failed to follow CDCR’s regulations (Cal. Code Reg., tit. 15, §§ 3084.3, 3084.6). Williams refiled the lost-property appeal two more times, but did not correct the mistakes, and CDCR ultimately cancelled it. Williams appealed the cancellation of his lost-property appeal, but it was rejected and cancelled. Williams filed an original habeas petition in the Court of Appeal alleging that CDCR violated his due process rights and rights under CDCR regulations by improperly cancelling his lost-property appeal. Held: Petition denied. Although habeas corpus jurisdiction has been expanded to encompass challenges to illegal conditions of confinement, a deprivation caused “by prison conditions or a prison regulation does not reach protected liberty interest status requiring procedural due process protection unless it imposes an atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life.” (Sandin v. Conner (1995) 515 U.S. 472, 484.) Here, Williams failed to show that the manner in which prison officials processed his lost-property appeal implicates any liberty interest protected by the due process clause “because inmates lack a separate constitutional entitlement to a specific prison grievance procedure.” (Ramirez v. Galaza (9th Cir. 2003) 334 F.3d 850, 860.) Based on this, the Court of Appeal concluded Williams’s petition did not meet California’s habeas corpus jurisdictional requirements.