Superintendent v. Hill

In Superintendent v. Hill, 472 U.S. 445 (1985) the United States Supreme Court determined there was "some evidence" that inmates Hill and Crawford were guilty of assault where the prison guard found another inmate bleeding around the mouth, observed evidence of a scuffle and saw three inmates, including Hill, jogging away from the scene. (Hill, supra, 472 U.S. at p. 447.) The court acknowledged that "although the evidence in the case might be characterized as meager, and there was no direct evidence identifying any one of the three inmates as the assailant, the record was not so devoid of evidence that the findings of the disciplinary board were without support or otherwise arbitrary." (Id. at p. 457.) "Ascertaining whether this standard is satisfied does not require examination of the entire record, independent assessment of the credibility of witnesses, or weighing of the evidence. Instead, the relevant question is whether there is any evidence in the record that could support the conclusion reached by the disciplinary board." (Hill, supra, 472 U.S. at pp. 455-456.) the United States Supreme Court considered the necessary quantum of evidence to satisfy the demands of due process: "We hold that the requirements of due process are satisfied if some evidence supports the decision by the prison disciplinary board ... . This standard is met if 'there was some evidence from which the conclusion of the administrative tribunal could be deduced ... .' Ascertaining whether this standard is satisfied does not require examination of the entire record, independent assessment of the credibility of witnesses, or weighing of the evidence. Instead, the relevant question is whether there is any evidence in the record that could support the conclusion reached by the disciplinary board." (Id. at pp. 455-456.) Procedural due process is not satisfied unless there is some evidence in the record that supports the findings of the prison disciplinary board. (Superintendent, supra, 472 U.S. 445, 454.) The "some evidence" standard does not require an independent inquiry into the entire record, the credibility of witnesses or the weight of evidence. (Id. at p. 455.) Instead, the Court needs only to look for "any evidence in the record that could support the conclusion reached by the disciplinary board. . . . The fundamental fairness guaranteed by the Due Process Clause does not require courts to set aside decisions of prison administrators that have some basis in fact." (Id. at pp. 455-456.) This standard is intentionally deferential to account for the unique circumstances of prison because although a forfeiture of good-time credits may implicate due process, the protection afforded does not compare to the liberty interests at the time of a criminal conviction. (Id. at p. 456.) In Hill, the United States Supreme Court declined to adopt a more stringent constitutional standard, observing that "prison disciplinary proceedings take place in a highly charged atmosphere, and prison administrators must often act swiftly on the basis of evidence that might be insufficient in less exigent circumstances. The United States Supreme Court concluded that "the fundamental fairness guaranteed by the Due Process Clause does not require courts to set aside decisions of prison administrators that have some basis in fact. Revocation of good time credit is not comparable to a criminal conviction and neither the amount of evidence necessary to support such a conviction nor any other standard greater than some evidence applies in this context." (Hill, supra, 472 U.S. at p. 456.)