LOCATION: We’ll Do Club
DOCKET NO.: 84-438
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: Massachusetts Supreme Judicial Court
CITATION: 472 US 445 (1985)
ARGUED: Mar 25, 1985
DECIDED: Jun 17, 1985
Barbara A. H. Smith - on behalf of the Petitioner
Jamie Ann Sabino - on behalf of the Respondents
Facts of the case
Media for Superintendent, Massachusetts Correctional Institution at Walpole v. Hill
Audio Transcription for Oral Argument - March 25, 1985 in Superintendent, Massachusetts Correctional Institution at Walpole v. Hill
Warren E. Burger:
We'll hear arguments next in Massachusetts Correctional Institution against Hill.
Ms. Smith, I think you may proceed whenever you are ready.
Barbara A. H. Smith:
Mr. Chief Justice and may it please the Court, the particular issues that we bring to this Court for review are whether the due process clause of the United States Constitution as held by the Supreme Judicial Court of Massachusetts requires judicial review of the sufficiency of the factual findings of the Prison Disciplinary Board when those findings form the basis for a loss of good time credits to inmates.
Second, assuming that judicial review is required, whether the Constitution requires any greater scrutiny than inquiry into whether the decision is supported by some or any facts.
The particular issues, however, I think implicate a much more fundamental and far-reaching issue, and that is the extent to which the Court will involve itself in the internal decisionmaking ability of prison administrators.
This case concerns what I believe is a very central concern of the prison system and that is the ability of the administrators to maintain discipline within the system.
This decision goes far beyond merely requiring certain procedural requirements of the disciplinary hearing, but indeed establishes the court as the ultimate fact finder in this area.
To subject the internal determinations regarding discipline to judicial second-guessing will result in substantial disruption to the prison system, to unnecessary but increasing demands on the judiciary, and will result in minimal salutary benefit to the inmates.
Now, the specific incidents which give rise to the instant case are as follows.
I will be very brief.
A guard on duty at a wing door into the yard at Walpole State Prison heard an inmate call out, "What's going on here"?
The guard moved to a window in the door leading out to the yard, where he again heard the inmate call out, "What's going on here"?
He peered out the window, observed a commotion, opened the door, and found the inmate bleeding from his mouth, with a puffed eye.
He immediately observed three inmates jogging away down a closed-in walkway into the regular yard.
Disciplinary reports issued and a hearing was held for each inmate.
The reporting officer testified substantially as I have just described.
However, in the hearing for innate Crawford... Hill... I'm sorry... the officer testified that a medic had told him that the injuries were consistent with the inmate having been beaten.
Crawford testified that he knew nothing of the event and offered an affidavit from the injured inmate that Crawford had not been involved.
Hill also testified that he knew nothing about the event.
The Board found the inmates guilty and ordered loss of 100 days' good time credits.
Hill and Crawford appealed to the Superintendent who affirmed the decision of the Disciplinary Board.
By regulation, the Commissioner of Correction also reviews any loss of good time cases.
The inmates then filed a pro se complaint in the Superior Court of Massachusetts, alleging that the evidence was insufficient to support the finding of the Disciplinary Board.
The Superior Court, having reviewed the Disciplinary Board's findings, concluded that as a matter of law the Board's findings of guilty rested on no evidence constitutionally adequate to support the findings of the Board.
May I ask, Ms. Smith, I gather that Massachusetts practice provides for this review in Superior Court, does it?
Barbara A. H. Smith:
I believe it provides only as a result of the Supreme Judicial Court held in this case.
Now, the Superintendent appealed the Superior Court Decision, alleging that there was no constitutional right to judicial review of this nature, of the sufficiency of the findings.
The Supreme Judicial Court held that there is no statutory right of review in Massachusetts for issues of this nature, but that its reading of Wolff v. McDonnell, it felt, logically entitled an inmate to judicial review as a matter of constitutional law.
Therefore, having reached this result, the Court construed Massachusetts law, particularly the certiorari aspect of Massachusetts law, as providing the appropriate vehicle for raising this constitutional claim; not that it was an independent statutory right, independent of the constitutional finding.
How much of this is state law?