Jose Ramirez v. Tracy Nietzel

Summary

The court held that prison disciplinary proceedings violated Ramirez's procedural due-process rights because the adjustment officer gave only a conclusory institutional-safety reason for refusing a requested witness and refused to review requested surveillance footage. The court required a sufficiently specific justification for denying witness testimony or inmate access to evidence, while permitting in-camera or sealed review when institutional concerns warrant it. The court reversed the appellate decision, vacated the circuit court's judgment, and remanded for in-camera review and further proceedings.