BONHAM v. BEAN (2026)

ORDER OF AFFIRMANCE

Following a Nevada Department of Corrections disciplinary hearing, Bonham was found guilty of verbal abuse and lost 15 days of canteen and phone privileges. Bonham filed a postconviction petition for a writ of habeas corpus, arguing his due process rights were violated during disciplinary proceedings because he received neither a timely notice of charges nor a timely disciplinary hearing. He contended the prolonged disciplinary process caused him to lose his job, such that he was no longer earning work credits. The district court denied Bonham's petition because his claims were not cognizable in a postconviction habeas petition as Bonham did not demonstrate he lost statutory credits.

Because Bonham did not lose any earned statutory credits as a result of prison disciplinary proceedings, we conclude the district court correctly determined that Bonham's claims were not cognizable in a petition for a writ of habeas corpus filed in state court. See NRS 34.724(1) (limiting postconviction habeas petitions to claims challenging the conviction, sentence, or computation of time served); Bowen v. Warden, 100 Nev. 489, 490, 686 P.2d 250, 250 (1984) (holding “a petition for writ of habeas corpus may challenge the validity of current confinement, but not the conditions thereof”); see also Vickers v. Dzurenda, 134 Nev. 747, 748, 433 P.3d 306, 308 (Ct. App. 2018) (holding that a prisoner who does not work while in prison is not entitled to work credits). Therefore, we conclude the district court did not err by denying Bonham's petition.

To the extent Bonham makes an independent challenge as to the computation of time served because he was unable to earn work credit, that claim is further barred because he did not allege sufficient facts that he had exhausted his administrative remedies. See Hall v. Oliver, 141 Nev., Adv. Op. 70, 584 P.3d 161, 164 (Ct. App. 2025); see also NRS 34.724(1). Therefore, we conclude Bonham was not entitled to relief, and we

ORDER the judgment of the district court AFFIRMED.