The opinion
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF PENNSYLVANIA
RICKY LYNN HATFIELD, :
:
Petitioner CIVIL ACTION NO. 3:24-1531
:
v. (JUDGE MANNION)
:
PENNSYLVANIA BOARD
OF PAROLE, et al., :
Respondents :
MEMORANDUM
Presently before the court is a pro se petition for writ of habeas corpus
filed pursuant to 28 U.S.C. §2254 to challenge a denial of parole. The petition
will be denied and a certificate of appealability will not issue.
I. BACKGROUND
Petitioner, Ricky Lynn Hatfield, is incarcerated in Mahanoy State
Correctional Institution (“SCI-Mahanoy”) pursuant to a state criminal
conviction. He brings the instant case under 28 U.S.C. §2254 to challenge
the denial of his parole by the Pennsylvania Parole Board. (Doc. 1). Hatfield
asserts that the denial of parole violated his constitutional right to due
process because it was based on arbitrary considerations. (Id.) Respondents
responded to the petition on November 12, 2024. (Doc. 11). Respondents
argue that the petition should be dismissed for failure to exhaust state court
remedies or, alternatively, denied on its merits. (Id.) Hatfield filed a reply brief
on November 29, 2024, making the petition ripe for review. (Doc. 10).
II. STANDARD OF REVIEW
A challenge to the denial of parole is cognizable under Section 2254.
Coady v. Vaughn, 251 F.3d 480, 486 (3d Cir. 2001). However, a federal
district court may not grant parole or determine parole eligibility. Billiteri v.
U.S. Bd. of Parole, 541 F.2d 938, 944 (2d Cir. 1976). “The only remedy which
the court can give is to order the Board to correct the abuses or wrongful
conduct within a fixed period of time, after which, in the case of non-
compliance, the court can grant the writ of habeas corpus and order the
prisoner discharged from custody.” Id.
III. DISCUSSION
“[T]here is no constitutional or inherent right of a convicted person to
be conditionally released before the expiration of a valid sentence,” nor has
the Commonwealth of Pennsylvania created such a right. Greenholtz v.
Inmates of Neb. Penal & Corr. Complex, 442 U.S. 1, 7 (1979). Thus, because
the denial of parole “does not implicate any constitutionally [or state]
protected liberty interest,” the scope of federal judicial review of state parole
denials is limited. Diehl-Armstrong v. Pa. Bd. of Prob. & Parole, No. 13-CV-
2302, 2014 WL 1871509, at *5 (M.D. Pa. May 7, 2014). The federal court is
confined to reviewing the substance of the state parole decision to determine
whether the Parole Board exercised its authority in an arbitrary and
capricious, or constitutionally impermissible manner. Block v. Potter, 631
F.2d 233, 236 (3d Cir. 1980).
To show a violation of substantive due process, a habeas petitioner
must demonstrate that: (1) he was arbitrarily denied parole due to
impermissible reasons such as race, religion, or political beliefs, and/or (2)
the Parole Board failed to apply appropriate, rational criteria in reaching its
determination to deny parole. Id. “However, federal courts are not authorized
by the due process clause to second-guess parole boards and the
requirements of substantive due process are met if there is some basis for
the challenged decision.” Coady, 251 F.3d at 487. The “relevant level of
arbitrariness required to find a substantive due process violation involves not
merely action that is unreasonable, but, rather, something more egregious,
which we have termed at times ‘conscience shocking’ or ‘deliberately
indifferent.’” Hunterson v. DiSabato, 308 F.3d 236, 247 (3d Cir. 2002).
In this case, Hatfield asserts that the denial of his application for parole
violated his right to due process. (Doc. 1). Respondents contend the petition
should be dismissed for failure to exhaust or denied on its merits. (Doc. 9).
At the outset, the court finds respondents’ exhaustion argument
unavailing. This court recently rejected an essentially identical argument for
failure to exhaust state court remedies in Mathis v. Rivello, No. 3:23-CV-225,
2025 WL 524301, at *7-8 (M.D. Pa. Feb. 18, 2025) (Mannion, J.). In Mathis,
the court held that Defoy v. McCullough, 393 F.3d 439, 445 (3d Cir. 2005),
remains good law and compels the conclusion that habeas petitioners
challenging the denial of parole are not required to exhaust remedies through
Pennsylvania state courts before they may file in federal court. Mathis, 2025
WL 524301, at *8. The court does not see any sound basis to reach a
contrary conclusion in this case and accordingly holds that dismissal of the
petition for failure to exhaust state court remedies is not warranted.
Turning to the merits, Hatfield acknowledges that he was denied parole
based on a finding that he posed a risk to the community and that he has an
unsatisfactory supervision history, but he argues the denial was “arbitrary”
because it was “contrary to all the things [he] has accomplished during his
incarceration,” which “clearly demonstrate he has rehabilitated himself.”
(Doc. 1 at 2). Hatfield argues that if a jury reviewed his record, it “would agree
that the Parole Board’s decision was an abuse of discretion.” (Id. at 3).
Hatfield’s argument amounts to a mere disagreement with the parole
board’s determination, which is not sufficient to obtain relief. See, e.g., Ball
v. Bohenski, No. 1:25-CV-1293, 2025 WL 2638364, at *3 (M.D. Pa. Sept. 12,
2025); Ordiway v. Pa. Bd. of Parole, No. 3:24-CV-741, 2024 WL 2214694,
at *2 (M.D. Pa. May 15, 2024); Picarella v. Wetzel, No. 1:19-CV-382, 2021
WL 199356, at *4 (M.D. Pa. Jan. 20, 2021). The parole board’s determination
that Hatfield posed a risk to the community and had an unsatisfactory history
during his incarceration presented “some basis for the challenged decision.”
Coady, 251 F.3d at 487. Hatfield’s unsupported disagreement does not
establish that the board violated his right to due process.
IV. CONCLUSION
For the foregoing reasons, the court will deny the petition for writ of
habeas corpus. A certificate of appealability will not issue because no
reasonable jurist would disagree with this ruling or conclude that the issues
presented are adequate to deserve encouragement to proceed further. Buck
v. Davis, 580 U.S. 100, 115 (2017) (citing Miller-El v. Cockrell, 537 U.S. 322,
336 (2003)). An appropriate order shall issue.
s/ Malachy E. Mannion
Malachy E. Mannion
United States District Judge
Dated: September 17, 2025
24-1531-01