Sandin v. Conner Case Brief

Why is the case important?

DeMont Conner was an inmate in the Halawa Correctional Facility, a maximum security prison in Oahu. When subjected to a strip search, Conner responded with angry and foul language at the officer. Conner was charged with “high misconduct,” the adjustment committee sentenced him to 30 days of segregation, without allowing Conner to present witnesses.

Facts of the case

Question

Under what circumstances do state prison regulations afford inmates a liberty interest under the Due Process Clause?

Answer

Reversed the Court of Appeals. Neither the Hawaii prison regulations nor the Due Process Clause afforded Conner a protected liberty interest that would entitle him to the procedural protections set forth in Wolff. Conner’s discipline in segregated confinement did not present the type of atypical, significant deprivation in which a state might conceivably create a liberty interest. Conner’s confinement did not exceed similar but totally discretionary confinement in duration or degree of restriction. Dissent. Justice Ginsburg and Justice Stevens: Conner had a liberty interest protected by the Fourteenth Amendment because confinement for high misconduct adds a stigma that could diminish parole prospects. Justice Breyer and Justice Souter: The majority radically changed the standard by setting a minimum standard, namely that a deprivation falls within the definition of a liberty only if it imposes atypical hardship on the inmate in relation to the ordinary incidents of prison life. Some lower courts may read this as affording much less protection, while others may find it an extension of protection for atypical hardships. Concurrence. None.

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.

  • Case Brief: 1995
  • Petitioner: Sandin
  • Respondent: Conner et al.
  • Decided by: Rehnquist Court

Citation: 515 US 472 (1995)
Argued: Feb 28, 1995
Decided: Jun 19, 1995