Sandin v. Conner

PETITIONER: Sandin
RESPONDENT: Conner et al.
LOCATION: South Boston Allied War Veterans Council

DOCKET NO.: 93-1911
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 515 US 472 (1995)
ARGUED: Feb 28, 1995
DECIDED: Jun 19, 1995

ADVOCATES:
Paul L. Hoffman - on behalf of the Respondents
Steven S. Michaels - on behalf of the Petitioner

Facts of the case

Question

Media for Sandin v. Conner

Audio Transcription for Oral Argument - February 28, 1995 in Sandin v. Conner

Audio Transcription for Opinion Announcement - June 19, 1995 in Sandin v. Conner

William H. Rehnquist:

I have the opinion of the Court to announce in number 93-1911 Sandin against Conner.

In this case prison officials alleged that respondent Conner who was a prisoner in Hawaii violated prison regulations by obstructing a physical inspection.

After a disciplinary hearing, a committee punished Conner with 30-days in disciplinary segregation.

He then filed a suit under Section 1983 claiming that prison officials deprived him of procedural due process because they didn’t allow him to call witnesses at this disciplinary hearing.

The Court of Appeals for the Ninth Circuit ruled in favor of Conner but in an opinion filed today with the clerk we reverse that decision.

Procedural due process claims in the prison context have been analyzed under various frameworks since this Court decided the cases of Wolff against McDonnell and Meachum v. Fano 20 years ago.

At that time, the Court defined liberty interest by inquiring whether the deprivation was one of real substance and whether was outside the normal limits or range of custody which the basic judgment of conviction authorized the State to impose.

Later the Court shifted focus in determining whether a state had created a liberty interest directing its attention to other prison regulations contained, mandatory language and substantive predicates.

We now think this approach was flawed, it encourages prisoners to comb regulations in search of mandatory language, it creates disincentives for a States to codify prison management procedures and it involves Federal Courts in the day-to-day management of prisons.

So, in this case we return to the principles established in Wolff and Meachum States may under certain circumstance create liberty interests which are protected by the due process clause but they are limited to freedom from restraint which would impose atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life.

The punishment imposed on Conner does not depart from the basic conditions of his sentence nor effect the duration of his sentence in any but a highly speculative way.

Justice Ginsberg has filed a dissenting opinion in which Justice Stevens joins; Justice Breyer has filed a dissenting opinion in which Justice Souter joins.