In Wolff v. McDonnell , 418 U.S. 539 (1976), the respondent, on his own behalf and that of other inmates at Nebraska prison, filed a complaint about the damages and injunctive relief under 42 U.S.C. In the petition, he argued that the disciplinary proceedings at the prison had violated the due process, the legal assistance programs of the inmates did not meet the constitutional standards and that the regulations governing the inmates' mail were so restrictive and unconstitutional. The District Court granted partial relief, ruling that the regulations governing the restrictions of the inmates' mail were unconstitutional, but holding that the restriction on the inmate legal assistance was not constitutionally illegal. However, the Court of Appeals, while referring to decisions in Morrissey v. Brewer , 408 U. S. 471, and Gagnon v. Scarpelli, 411 U. S. 778, held that inmates have the right to due process. On the disciplinary cell ruling, the court ruled that confinement in the disciplinary cells is only provided for serious misconduct and deprivation of privileges in the less serious misconduct. Both the scheduled segregation and loss of commissary privileges are only provided for serious misconduct. Establishing the misconduct require a preliminary conference to be held and the inmate informed of the charges by the prison disciplinary body ( Richmond, 2015 ).
While the Court of Appeal held that the restoration of good time and commissary benefits is foreclosed, there are damages and relief that come with illegal revocation of the good time credits as recognized the constitution under 418 U. S. 553-555 ( Richmond, 2015 ). The court noted that an inmate is not entirely denied the constitutional protections and the right to liberty. The court of appeal further held that since the inmates at Nebraska prison can only lose good times and get to scheduled segregation if they are found to have committed serious misconducts, there is the procedure for determining whether the misconduct has occurred and whether it is serious. This procedure must observe the due process as required, meaning that the prisoner must be provided with legal assistance. Furthermore, a charge notice must be given to the inmates concerning the disciplinary action at least 24 hours before he appears before the committee. The prisoner must also be allowed to call a witness and provide evidence to defend himself against the allegations.
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While the penal system of Nebraska states serious misconduct is punishable by either withholding the good time and commissary privileges and confinement in the disciplinary segregation, the Court of Appeal held that the constitution protects the prisoners and the right to due legal process even though their liberty rights have been limited with the prison environment ( Schlanger, Love & Reynolds, 2010 ). Therefore, to confirm that an inmate has been involved in serious misconduct that requires either withholding of the good time and privileges and being taken for segregation, a due process is needed where the prisoners must be allowed to provide witnesses and evidence for their defense. It must involve the balance between individual constitutional rights and individual institutional needs. The disciplinary hearing of the prisoners plays a crucial role in determining the kind of confinement they will receive and whether their good time credits will be withdrawn. Based on this, such a hearing is important to the inmates and must, therefore, be conducted in a manner that respects the rights of an individual while also remaining within the constitutional requirements. In the Nebraska prison, the committee stated that an inmate did not have the right to call the witness or provide documentary evidence for the defense. However, the court held that prisoners had to be given notice 24 hours earlier, be allowed to call witnesses and present documentary evidence in defense. In this, the court views due process as to have more rights to the inmates and ensures that fairness is availed during the hearing before an inmate is denied certain privileges.
The court of appeal ruling on Wolff v. McDonnell (1974) came as a relief to the prisoners and changed the way prisoners are punished. It prevented the incidences where inmates are subjected to schedules segregation or good credit time and other privileges withheld even when one was innocent because they are not given time to defend themselves. Without the ability to call the witness or even provide documentary evidence in defense, inmates would definitely become losers in the hearing irrespective of whether they were innocent or not. Without the ability to call the witness or provide evidence for the defense, an inmate is less likely to receive an issue of credibility when facing charges of serious misconduct. Also, it is an infringement of the rights of prisoners for the sake of administration because due process calls for the acceptance of higher values as opposed to efficiency. In the ruling, Justice Marshall provided a solution to a serious problem which had been in our prisons where the inmates’ rights and privileges have continuously been violated against the constitutional requirements.
One major issue arises based on the ruling by Justice Marshall, the limitation of the liberty of prisoners does not necessarily lead to loss of the rights to due process in a way that further restricts the freedom. Every liberty lost by the prisoner require procedural protection as every prisoner have some liberty that should be protected. While the court did not deter the prison officials from subjecting the misbehaved prisoners to segregated confinement and withdrawal of good time credit and other privileges, it sought to ensure that no prisoner had their liberty rights stripped off without going through sufficient procedural process and offered a chance to defend themselves ( Richmond, 2015 ). The ruling by justice Marshall, therefore, made a significant impact towards protecting the privileges and liberty of the inmates by ensuring they are taken through due process before determining if they have committed serious misconduct that is worth segregation and withdrawal of privileges. The impact of this case on the prison management is that it led to more protection of the liberty rights of the prisoners and ensuring that there was fairness in determining what constitutes serious misconduct before one can be confined or denied good time credit
In 1995, the Supreme Court decided on the case concerning the solitary confinement in Sandin v. Conner . The court decided that atypical and significant hardship must be present in the solitary confinement if a prisoner is to be given due process protection. This decision was not in comport with the ruling on the Wolff v. McDonnell in 1974 which stated that due process was a constitutional right for the inmates and cannot be taken away by the prison officials. However, the Supreme Court rejected this, instead focusing on the nature of deprivation in the determination of whether an inmate needs a due process. In the ruling, the court stated that Conner’s punishment did not involve atypical and significant hardship and therefore cannot guarantee him the right to due process ( Henderson, 2015 ). This ruling was a setback to the prisoners whose liberty rights had been limited by being denied the chance to call a witness and present documentary evidence in their defense.
While the judgment in the Sandin v. Conner case made an assumption that solitary confinement is more effective in the management of prisons and promotes the prisoner rehabilitative objectives, there is no evidence to support this. Instead, evidence has confirmed that the use of solitary confinement and withdrawal of the privileges limits the effective management of prisons and increase the chances of the prisoners repeating the offense ( Cassel, 2012 ). Also, the report by the GAO has shown that solitary confinement brings in the need to hire more prison administrators and raises the cost with the availability of limited resources. As more prisoners are taken to solitary confinement, the need to employ more prison administrators arises and this calls for more resources to be allocated to this department at a time when the process itself has been proved to yield no positive result on the inmates. Even after the inmates are taken to solitary confinement and privileges withdrawn, there is no evidence to show that they change from doing serious misconduct. This then goes against the goal of prison administrators, which is to help rehabilitate the prisoners and turn them to law-abiding citizens. The Supreme Court ruling on Sandin v. Conner also creates more effects to prisoners in that disciplinary segregation have been found to have higher rates of recidivism. Most people after getting out of the disciplinary recidivism to tend to repeat the crime thus rendering the process ineffective in rehabilitating the offenders ( Marcus, 2014 ).
In conclusion, the court of Appeal ruling on Wolff v. McDonnell (1974) came as a relief to the prisoners because it promoted the protection of liberty rights and the use of due process to determine the serious misconduct. This ensured that there were fairness and the number of people taken to solitary confinement reduced. However, the 1995 ruling by the Supreme Court on Sandin v. Conner reversed the situation, allowing the prison officials to exercise disciplinary segregation to inmates without allowing them to present evidence and witness in their defense. This has created a lot of unfairness to prisoners, leading to a high number of segregated inmates which only increase the costs with limited chances of efficiency.
References
Cassel, K. (2012). Due Process in Prison: Protecting inmates' property after SANDIN V. CONNER. Colum. L. Rev. , 112 , 2110.
Henderson, G. (2015). Disciplinary Segregation: How the Punitive Solitary Confinement Policy in Federal Prisions Violates the Due Process Clause of the Fifth Amendment in Spite of Sandin V. Conner. Marq. L. Rev. , 99 , 477.
Marcus, E. (2014). Toward a Standard of Meaningful Review: Examining the Actual Protections Afforded to Prisoners in Long-Term Solitary Confinement. U. Pa. L. Rev. , 163 , 1159.
Richmond, C. (2015). Toward a More Constitutional Approach to Solitary Confinement: The Case for Reform. Harv. J. on Legis. , 52 , 1.
Schlanger, M., Love, M. C., & Reynolds, C. (2010). ABA Criminal Justice Standards on the Treatment of Prisoners. Crim. Just. , 25 , 14.
