The applicant, a federal inmate, sought habeas corpus challenging an emergency involuntary transfer from a minimum‑security institution to a medium‑security institution.
The court held that correctional authorities failed to disclose key information relied upon in the reclassification decision, including communications with police and details underlying the security reclassification scale.
The court also found a reasonable apprehension of bias arising from the conduct of the parole officer and the warden in seeking prejudicial information to support the transfer decision while withholding it from the inmate.
Applying the Supreme Court’s framework in Mission Institution v. Khela, the court concluded that the transfer decision was unreasonable and therefore unlawful.
The transfer decision was quashed and the inmate was ordered returned to minimum security.
