Wolff v. McDonnell

Facts of the Case

Robert O. McDonnell, on behalf of himself and other inmates at a Nebraska prison, filed a complaint for damages and injunctive relief under

Question

Do the disciplinary proceedings at Nebraska Penal and Correctional Center violate the Due Process Clause of the Fourteenth Amendment?

CONCLUSION

Yes. In a 6-3 vote Justice Byron R. White wrote for the majority reversing in part and affirming in part. The Supreme Court held that while prisoners are not entitled to full due process protections, disciplinary proceedings must include written notice to the defendant of the charges, a written statement of evidence, and the opportunity for an inmate to call witnesses and present evidence. The Court allowed for discretion by officials to deny a prisoner the right to present evidence or call witnesses if it would be unduly hazardous to institutional safety. The Court also held that prison official’s opening of privileged letters in the presence of other inmates was not unconstitutional.Justice Thurgood Marshall dissented in part, stating that the inmate’s right to present evidence and call witnesses is constitutionally protected and should not be abridged. Justice William J. Brennan Jr. joined. Justice Douglass wrote a dissent, saying that prisoners are entitled to all due process protections when they are faced with an substantial deprivation of liberty in the prison.

Case Information

  • Citation: 418 US 539 (1974)
  • Argued: Apr 22, 1974
  • Decided Jun 26, 1974