In Wolff v. McDonnell, 418 U.S. 539 (1974), the court held that Nebraska prisoners whose good time credits could be forfeited if they were guilty of violating prison rules were entitled to certain minimal due process safeguards before such credits could be deducted: (1) advance written notice of the claimed violation of prison rules; (2) a hearing at which the prisoner had the right to call witnesses and present evidence, so long as institutional security was not threatened thereby; (3) where necessary because of the prisoner's illiteracy or the complexity of the issues, assistance from other inmates or staff; (4) a written record of the proceedings, including a statement by the factfinder as to the evidence relied upon and the reasons for the disciplinary action taken. ( Id. at pp. 563-566.) The United States Supreme Court recognized that, while many of the rights and privileges of a citizen may be diminished or be unavailable because of considerations of our penal system and the needs and exigencies of the institutional environment, a prisoner is not wholly stripped of constitutional protections when he is imprisoned. The court held that prisoners retain rights under the due process clause of the United States Constituion, and that although these rights are "subject to restrictions imposed by the nature of the regime to which they have been lawfully committed..., there must be mutual accommodation between institutional needs and objectives and the provisions of the Constitution that are of general application." ( Wolff v. McDonnell, supra, 418 U.S. 539, 556.) Applying this accommodation principle to procedures established by the State of Nebraska for depriving prisoners of "good-time credits," the court held that where the state itself has not only provided a statutory right to good time but also specifies that it is to be forfeited only for serious misbehavior, the prisoner's interest has real substance and is sufficient to constitute a "liberty" interest within the Fourteenth Amendment entitling him to "those minimum procedures appropriate under the circumstances and required by the Due Process Clause to insure that the state-created right is not arbitrarily abrogated." ( Wolff v. McDonnell, supra, 418 U.S. 539, 557.) In Wolff, the law under which the prisoner was confined provided for the accural of good time credits based upon good conduct and the fact of misconduct was the condition for the loss of such benefits. Under these circumstances the court held that a fact finding process was necessary to avoid arbitrary action by the prison administration. ( Wolff v. McDonnell, supra, 418 U.S. 539, 558 41 L.Ed.2d 935, 952, 94 S.Ct. 2963.) In Wolff v. McDonnell, 418 U.S. 539, the Supreme Court of the United States also identified an inmate's fundamental due process right to a written statement setting forth the evidence relied upon by the fact finder and the reason(s) for the disciplinary action taken. Id. at 564-565. In this regard the Wolff noted that "written records of disciplinary proceedings will . . . protect the inmate against collateral consequences based on a misunderstanding of the nature of the original proceeding. Further, as to the disciplinary action itself, the provision for a written record helps to insure that administrators, faced with possible scrutiny by state officials and the public, and perhaps even the courts, where fundamental constitutional rights may have been abridged, will act fairly. Without written records, the inmate will be at a severe disadvantage in propounding his own cause to or defending himself from others." Id. at 565. In Wolff v. McDonnell was significant because it established the due process protections. The court observed that, although loss of custody credits does not visit "the same immediate disaster that the revocation of parole is for the parolee," the loss of such credits "can postpone the date of eligibility for parole and extend the maximum term to be served, but it is not certain to do so, for good time may be restored. Even if not restored, it cannot be said with certainty that the actual date of parole will be affected; and if parole occurs, the extension of the maximum term resulting from loss of good time may affect only the termination of parole, and it may not even do that. The deprivation of good time is unquestionably a matter of considerable importance. The State reserves it as a sanction for serious misconduct, and we should not unrealistically discount its significance." (Wolff, supra, 418 U.S. at p. 561.) Thus, although Wolff acknowledged loss of credits may merely serve to delay parole, it nevertheless concluded some level of due process was required if the state moved to require the inmate to forfeit those credits and thereby delay his parole.