Zelos Fields v. J. Norwood

MEMORANDUM

Federal prisoner Zelos Fields appeals pro se from the district court’s judgment denying his 28 U.S.C. § 2241 habeas petition. We have jurisdiction under 28 U.S.C. § 1291 , and we affirm.

Fields challenges a prison disciplinary violation that resulted in the loss of good conduct time, contending that his right to due process was violated because he was denied staff representation at his hearing, and because he did not knowingly or voluntarily waive his right to staff representation. We review the denial of a section 2241 habeas petition de novo. See Tabla-da v. Thomas, 533 F.3d 800, 805 (9th Cir. 2008).

The record reflects that Fields was afforded the minimal procedural protections to which he was entitled. See Wolff v. McDonnell, 418 U.S. 539, 563-67 , 94 S.Ct. 2963 , 41 L.Ed.2d 935 (1974). Contrary to Fields’s contention, his case was not so complicated as to entitle him to staff representation at his hearing. See id. at 570 (an inmate has a right to assistance jfrom a fellow inmate or staff where “the complexity of the issue makes it unlikely that the inmate will be able to collect and present the evidence necessary for an adequate comprehension of the case”).…