Christopher Coats v. Warden

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION CHRISTOPHER COATS, Petitioner, v. CAUSE NO. 3:26-CV-681-PPS-AZ WARDEN, Respondent.

OPINION AND ORDER Christopher Coats, a prisoner without a lawyer, filed a habeas corpus petition challenging the prison disciplinary hearing (WCC 25-11-7510) where a Disciplinary Hearing Officer (DHO) found him guilty of Possession of Intoxicating Substance in violation of B-231 on March 3, 2026. ECF 1. Coats was not sanctioned with either the loss of Earned Credit Time or a demotion in Credit Class. Id. A prison disciplinary action can only be challenged in a habeas corpus proceeding where it results in the lengthening of the duration of confinement. Hadley v. Holmes, 341 F.3d 661, 664 (7th Cir. 2003). Because the duration of his confinement was not lengthened by the prison disciplinary proceeding, this case must be dismissed under Section 2254 Habeas Corpus Rule 4 as “it plainly appears from the petition and any attached exhibits that the petitioner is not entitled to relief in the district court.”

If Coats wants to appeal this decision, he does not need a certificate of appealability because he is challenging a prison disciplinary proceeding. See Evans v. Circuit Court, 569 F.3d 665, 666 (7th Cir. 2009). However, he may not proceed in forma pauperis on appeal because an appeal could not be taken in good faith under 28 U.S.C. § 1915(a)(3).

For these reasons, the court: (1) DENIES the habeas corpus petition (ECF 1) under 2254 Habeas Corpus Rule 4; (2) DIRECTS the clerk to enter judgment and close this case; and (3) DENIES Christopher Coats leave to proceed in forma pauperis on appeal.

ENTERED: May 21, 2026. /s/ Philip P. Simon PHILIP P. SIMON, JUDGE UNITED STATES DISTRICT COURT