Sandin v. Conner

Supreme Court of the United States · 1995 · Administrative Law

Administrative LawFederal CourtsPrisoners' Due ProcessLiberty InterestsDue Process Clauseprison disciplinedisciplinary segregationstate-created liberty interest

Facts

DeMont Conner, a Hawaii prisoner serving an indeterminate sentence of 30 years to life, was charged with disciplinary infractions after responding angrily and obscenely to a strip search. At his disciplinary hearing, the adjustment committee refused his request to present witnesses, found him guilty, and sentenced him to 30 days of disciplinary segregation in the Special Holding Unit. Nine months later, on administrative review, the prison expunged the high misconduct charge from his record, but Conner had already served the segregation time and filed this § 1983 suit claiming a denial of procedural due process. The segregation conditions largely mirrored those imposed on inmates in administrative segregation and protective custody.

Issue

Whether Hawaii prison regulations or the Due Process Clause itself gave Conner a protected liberty interest in remaining free from 30 days of disciplinary segregation, such that he was entitled to the procedural protections described in Wolff. More broadly, the question was under what circumstances prison regulations create protected liberty interests for inmates.

Rule

States may under some circumstances create liberty interests protected by the Due Process Clause, but those interests are generally limited to freedom from restraint that, while not otherwise independently protected by the Due Process Clause, imposes atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life. The Court rejected the prior emphasis on mandatory regulatory language and negative implications drawn from prison regulations as the basis for finding liberty interests.

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At a state prison in Columbus, Ohio, Marcus Hale receives 21 days of disciplinary segregation after a hearing on a rule violation. The segregation unit uses the same single-cell housing, visitation limits, and daily schedule used for inmates placed there for administrative segregation and protective custody, and Ohio parole rules do not make misconduct findings dispositive of release.

If Marcus brings a § 1983 procedural due process claim arguing he was denied the right to present witnesses, which is the strongest argument for the prison officials?

Explanation. The majority held that a State-created liberty interest generally arises only when the restraint imposes an atypical and significant hardship in relation to the ordinary incidents of prison life. Short disciplinary segregation that mirrors administrative segregation and protective custody, and does not inevitably affect sentence duration, does not qualify. Therefore Marcus was not entitled to Wolff procedures on these facts. (Derived from Sandin v. Conner (1995).)