In Re Zepeda

Richard S. Zepeda, an inmate at Calipatria State Prison, petitioned the trial court for a writ of habeas corpus seeking reversal of disciplinary action imposed upon him by prison officials for possessing a weapon in violation of prison regulations. The court granted the relief requested, concluding that the evidence introduced at Zepeda’s prison disciplinary proceeding—consisting primarily of the weapon’s location in a cup on a shelf accessible to both Zepeda and his cellmate—was insufficient to support a finding that Zepeda possessed the weapon. Consequently, the court ruled, Zepeda’s punishment violated his rights to due process under the federal Constitution and must be reversed.

Stuart Ryan, warden of Calipatria State Prison (the Warden) and the respondent to Zepeda’s petition, appeals the trial court’s ruling. The Warden contends, and we agree, that given the extraordinarily deferential standard of review that applies when a. court reviews a challenge to prison disciplinary action on federal due process grounds, the trial court’s ruling was erroneous.

FACTS

On October 1, 2003, Correctional Sergeant J. Valenzuela conducted a routine search of prison cell 106, the…