Juan Zapata v. Warden Fci Edgefield

UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 26-6186
JUAN ZAPATA,
Petitioner - Appellant,
v.
WARDEN FCI EDGEFIELD,
Respondent - Appellee.
Appeal from the United States District Court for the District of South Carolina, at
Orangeburg. David C. Norton, District Judge. (5:25-cv-00635-DCN)
Submitted: April 23, 2026 Decided: April 28, 2026
Before NIEMEYER, THACKER, and HARRIS, Circuit Judges.
Affirmed by unpublished per curiam opinion.
Juan Zapata, Appellant Pro Se. Charles W. Scarborough, Jennifer L. Utrecht, UNITED
STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.
Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:
Juan Zapata, a federal prisoner, appeals the district court’s order accepting the
magistrate judge’s recommendation and denying relief on Zapata’s 28 U.S.C. § 2241
petition. In his petition, Zapata challenged a disciplinary hearing officer’s (“DHO”)
finding that he possessed a hazardous tool (a cellphone) and the resulting revocation of
good conduct time. We affirm.
“We review the district court’s denial of habeas corpus relief de novo.” Valladares
v. Ray, 130 F.4th 74, 80 (4th Cir. 2025). A finding of guilt in a prison disciplinary
proceeding must be supported by “some evidence.” Superintendent, Mass. Corr. Inst. v.
Hill, 472 U.S. 445, 455 (1985). “This is an exceedingly lenient standard, requiring only a
modicum of evidence in order to prevent arbitrary deprivations without threatening
institutional interests or imposing undue administrative burdens.” Tyler v. Hooks, 945 F.3d
159, 170 (4th Cir. 2019) (internal quotation marks omitted). “Ascertaining whether this
standard is satisfied does not require examination of the entire record, independent
assessment of the credibility of witnesses, or weighing of the evidence.” Hill, 472 U.S. at
455. Rather, “the relevant question is whether there is any evidence in the record that could
support the conclusion reached by the [DHO].” Id. at 455-56. But “if some evidence is to
be distinguished from no evidence, it must possess at least some minimal probative value
if it is to be found adequate to satisfy the requirements of the Due Process Clause that the
decisions of prison administrators must have some basis in fact.” Tyler, 945 F.3d at 171
(internal quotation marks omitted).

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After reviewing the record, we conclude that there was “some evidence” supporting
the revocation of Zapata’s good conduct time. The officer’s written report, Zapata’s
statement during the disciplinary hearing, the photograph of the phone, and Zapata’s
disciplinary record established, at a minimum, that he constructively possessed the phone.
Accordingly, we affirm the district court’s order. Zapata v. Warden FCI Edgefield, No.
5:25-cv-00635-DCN (D.S.C., Dec. 18, 2025). We dispense with oral argument because
the facts and legal contentions are adequately presented in the materials before this court
and argument would not aid the decisional process.
AFFIRMED

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