Citation: Sandin, Unit Team Manager, Halawa Correctional Facility v. Conner, 515 U.S. 472, 115 S. Ct. 2293, 132 L. Ed. 2d 418, 63 U.S.L.W. 4601, 95 Cal. Daily Op. Service 4627, 95 Daily Journal DAR 7920, 9 Fla. L. Weekly Fed. S 207 (U.S. June 19, 1995)
The case of Sandin v. Conner involves a constitutional challenge under the Due Process Clause of the Fourteenth Amendment. It concerns whether an inmate’s procedural due process rights were violated when he was placed in disciplinary segregation without being allowed to present witnesses during a disciplinary hearing.
The U.S. Supreme Court ultimately ruled on whether the Hawaii prison regulations and the Due Process Clause created a protected liberty interest that would entitle Conner to procedural protections, such as the ability to present witnesses. The Court’s decision in this case reshaped the standard for evaluating liberty interests of prisoners in disciplinary contexts.
Facts of Sandin, Unit Team Manager, Halawa Correctional Facility v. Conner
In 1988, DeMont Conner, an inmate at the Halawa Correctional Facility in Hawaii, was involved in an altercation with a prison officer. The incident occurred during a strip search, during which Conner used foul language and made an angry response to the officer. As a result, Conner was charged with high misconduct, and the adjustment committee sentenced him to 30 days in disciplinary segregation.
Conner sought due process protections because he was not allowed to present witnesses at his disciplinary hearing. He argued that the failure to allow him to call witnesses deprived him of his procedural due process rights under Wolff v. McDonnell, 418 U.S. 539 (1974), which guarantees certain rights to inmates during disciplinary hearings.
Despite the charge of misconduct, the Deputy Administrator later reviewed Conner’s case, found the misconduct charge unsupported, and expunged his record for the more serious charges. However, Conner sought injunctive relief, declaratory relief, and damages for the denial of procedural due process, asserting that his disciplinary segregation violated his rights.
The District Court granted summary judgment in favor of the prison officials, but the Ninth Circuit Court of Appeals reversed, stating that Conner had a liberty interest in remaining free from disciplinary segregation, and that there was a factual dispute about whether he received all the procedural protections owed under Wolff.
Issue
The central issue in Sandin v. Conner is whether Hawaii prison regulations, along with the Due Process Clause, afford DeMont Conner a protected liberty interest that would entitle him to the procedural protections set forth in Wolff v. McDonnell (the right to present witnesses and other procedural safeguards during a disciplinary hearing).
Legal Background
In Wolff v. McDonnell, the Supreme Court established the due process rights of prisoners during disciplinary hearings, stating that inmates are entitled to certain procedural protections when faced with disciplinary action that might deprive them of liberty interests, such as confinement in disciplinary segregation.
These protections include the right to a written statement of the charges, the opportunity to call witnesses and present evidence, and the right to be heard by an impartial decision-maker.
However, Wolff also established that not every confinement or restriction faced by an inmate creates a liberty interest that is protected by the Due Process Clause. The Court emphasized that a liberty interest arises only when the deprivation imposes an atypical and significant hardship in relation to the ordinary incidents of prison life.
In earlier cases such as Meachum v. Fano, 427 U.S. 215 (1976), and Hewitt v. Helms, 442 U.S. 460 (1983), the Court examined whether the nature of the deprivation, not the specific language in prison regulations, should determine the existence of a liberty interest.
In those cases, the Court focused on whether the prisoner’s confinement or segregation exceeded the usual conditions of prison life to the point that it affected their liberty in a way that required procedural protections.
Sandin, Unit Team Manager, Halawa Correctional Facility v. Conner Judgment
The Supreme Court, in its majority opinion delivered by Chief Justice Rehnquist, reversed the decision of the Ninth Circuit Court of Appeals, holding that Conner did not have a protected liberty interest that would require the procedural protections of Wolff v. McDonnell.
The Court’s analysis was based on the following key points:
No Significant or Atypical Hardship
- The Court concluded that Conner’s disciplinary segregation did not involve an atypical or significant deprivation of liberty.
- The conditions of his confinement were no different from those imposed in administrative segregation or protective custody, which were considered ordinary conditions of prison life.
- The Court noted that Conner’s segregation did not exceed similar confinement, either in terms of duration or degree of restriction.
- The Court emphasized that a liberty interest only arises when the deprivation imposes atypical and significant hardship relative to the ordinary incidents of prison life, and Conner’s case did not meet this threshold.
The Shift Away from Regulatory Language
- The Court rejected the methodology from Hewitt v. Helms, which focused on whether mandatory language in prison regulations created an expectation of a particular outcome.
- The Court found that this approach had led to prisoners scrutinizing prison regulations for mandatory language to assert liberty interests. This practice had created disincentives for states to codify prison management procedures and increased federal involvement in prison administration.
- Instead, the Court returned to the approach established in Wolff v. McDonnell and Meachum v. Fano, focusing on whether the deprivation of liberty imposed atypical and significant hardship relative to the ordinary conditions of prison life.
Conner’s Segregation Did Not Impact Parole
- The Court further reasoned that the segregation did not necessarily affect the duration of Conner’s sentence or his parole eligibility, as the misconduct finding was unlikely to have any direct impact on his parole statu
- The chance that disciplinary segregation would negatively affect Conner’s parole prospects was considered too attenuated to invoke Due Process protections under the Fourteenth Amendment.
Dissenting Opinions
While the majority ruled against Conner, there were dissenting opinions:
- Justice Ginsburg, joined by Justice Stevens, dissented, arguing that Conner did indeed have a liberty interest under the Fourteenth Amendment because his confinement for “high misconduct” could negatively impact his parole prospects and lead to stigmatization.
- Justice Breyer, joined by Justice Souter, expressed concern that the majority’s ruling established an overly narrow definition of liberty interests by setting a minimum standard that only protects prisoners from conditions that impose atypical and significant hardship. They worried this decision would result in uneven protection in different courts and provide less protection for inmates facing atypical hardships.
Conclusion
The Supreme Court’s ruling in Sandin v. Conner fundamentally reshaped the standard for evaluating prisoner liberty interests under the Due Process Clause. The Court reaffirmed that not all forms of confinement in prison entitle an inmate to procedural protections, like the right to present witnesses during a disciplinary hearing, and that liberty interests are only triggered when the conditions of confinement impose atypical and significant hardship beyond the ordinary incidents of prison life.
In this case, the Court found that Conner’s disciplinary segregation did not rise to the level of an atypical hardship, and thus, the Hawaii prison regulations did not create a liberty interest that would require procedural safeguards under Wolff v. McDonnell. As a result, Conner’s procedural due process claim was rejected, and the Court reversed the Ninth Circuit’s decision.