An amendment to the California state penal code under which a prison inmate who chose to remain an active gang member during his incarceration was placed in administrative segregation and deemed ineligible to earn sentence reduction conduct credits did not violate his rights against ex post facto punishment since his choice to remain in the gang continued after the passage of the provision. The court also found that the determination that he remained a gang member was adequately supported by "some evidence." In re Efstathiou, #C067807, 2011 Cal. App. Lexis 1381 (Cal. App.).
    White inmate's rights not violated by prison's policy of permitting gang membership while limiting gang activity. David K. v. Lane, 839 F.2d 1265 (7th Cir. 1988).