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Sandin v. Conner - 515 U.S. 472, 115 S. Ct. 2293 (1995)

Rule:

States may under certain circumstances create liberty interests which are protected by the Due Process Clause. But these interests will be generally limited to freedom from restraint which, while not exceeding the sentence in such an unexpected manner as to give rise to protection by the Due Process Clause of its own force, nonetheless imposes atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life.

Facts:

In this suit, respondent Conner alleged that petitioner and other Hawaii prison officials deprived him of procedural due process when an adjustment committee refused to allow him to present witnesses during a disciplinary hearing and then sentenced him to segregation for misconduct. The District Court granted the officials summary judgment, but the Court of Appeals reversed, concluding that Conner had a liberty interest in remaining free of disciplinary segregation and that there was a disputed question of fact whether he had received all of the process due under Wolff v. McDonnell, 418 U.S. 539, 41 L. Ed. 2d 935, 94 S. Ct. 2963

Issue:

Under either Hawaii prison regulation or the Due Process Clause, did Conner have a protected liberty interest that would entitle him to the procedural protections set forth in Wolff v. McDonnell?

Answer:

No

Conclusion:

Neither the Hawaii prison regulation nor the Due Process Clause itself affords Conner a protected liberty interest that would entitle him to the procedural protections set forth in Wolff. Under Wolff, States may in certain circumstances create liberty interests that are protected by the Due Process Clause. But these interests will generally be limited to freedom from restraint which, while not exceeding the sentence in such an unexpected manner as to give rise to protection by the Due Process Clause of its own force, nonetheless imposes atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life. However, The Court found that states may under certain circumstances create liberty interests that are protected by the Due Process Clause. However, the Court held that respondent prisoner's discipline in segregated confinement did not present the type of atypical, significant deprivation in which a state might conceivably create a liberty interest. The Court noted that the record showed that respondent's punishment, with insignificant exceptions, mirrored the conditions imposed upon inmates in administrative segregation and protective custody. Furthermore, the Court found that the regime respondent was subjected to as a result of the misconduct hearing was within the range of confinement normally expected for someone serving an indeterminate term of 30 years to life.

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