Thompson v. Owens

Opinion OF THE COURT BECKER, Circuit Judge Appellant David Thompson, an inmate confined at the State Correctional Institution at Rockview, Pennsylvania, brought this civil rights class action in the district court for the Middle District of Pennsylvania against various correctional officials, complaining that his due process rights had been violated by the officials' failure to provide complete chain of custody evidence at his misconduct hearing. Appellant tested positive on his urinalysis drug test and was convicted of misconduct. As a result of the conviction, appellant suffered a significant loss of benefits. He alleged in his complaint that, because there was no evidence of the chain of custody of his urine sample, test results based upon it could not be placed into evidence in the record of proceedings. Adopting the Magistrate's report, the district court dismissed the complaint, concluding that despite the absence of ""chain of custody"" evidence, the positive results of appellant's urinalysis tests amounted to ""some"" evidence sufficient to support a finding of misconduct and to satisfy due process (App. 49-55). The quantum of evidence necessary in the context of prisoner disciplinary proceedings was described by the Supreme Court in Superintendent v. Hill, 472 U.S. 445, 86 L. Ed. 2d 356, 105 S. Ct. 2768 (1985):