In re Rigsby

*1013 Respondent Christopher Rigsby is presently serving a life sentence for murder. In 2015, prison officials found him guilty of possessing contraband, which resulted in a 30-day loss of inmate privileges and early release credits. Rigsby challenged the disciplinary action by petitioning the Fresno Superior Court for a writ of habeas corpus. The superior court granted the petition, *563 concluding there was insufficient evidence to support the finding of constructive possession. The warden of Pleasant Valley State Prison (PVSP) appeals the superior court's ruling.

The warden's appeal is well taken. As we explain, the superior court's decision cannot be reconciled with the standard of review for prison disciplinary proceedings. Therefore, the order granting respondent's petition must be reversed.

FACTUAL AND PROCEDURAL BACKGROUND

In May 2015, prison officials at PVSP accused Rigsby of possessing a precursor ingredient for inmate-manufactured alcohol (i.e., "pruno"). In prison slang, the contraband is known as a "kicker." According to the record, a kicker is a concoction of bread, fruit, and sugar. Adding water and heat to the mixture "creates a fermenting process" eventually…