Can a Prisoner Sue for Damages In Connection With His Disciplinary Hearing ?
In Sandin v. Conner, 515 U.S. 472, 115 S. Ct. 2293, 132 L. Ed. 2d 418 (1995), the Supreme Court examined the circumstances under which state prison regulations afford inmates a liberty interest protected by the Due Process Clause of the Fourteenth Amendment.
Conner, an inmate at a Hawaii prison, was placed into disciplinary segregation for 30 days following an altercation with prison officials.
He filed suit seeking injunctive relief and damages for, inter alia, a deprivation of procedural due process in connection with his disciplinary hearing.
The Supreme Court devoted much of its analysis to clarifying the proper analytical framework for these types of claims, noting that previous decisions had impermissibly shifted the focus of the liberty interest inquiry from one based on the nature of the deprivation to one based on language of a particular prison regulation. Eschewing the increasing involvement of federal courts in the day-to-day management of prisons, the Court announced that the time had come to return to the due process principles established in Wolff v. McDonnell, 418 U.S. 539, 94 S. Ct. 2963, 41 L. Ed. 2d 935 (1974) and Meachum v. Fano, 427 U.S. 215, 96 S. Ct. 2532, 49 L. Ed. 2d 451 (1976).
Accordingly, the Court held:
Following Wolff, we recognize that States may under certain circumstances create liberty interests which are protected by the Due Process Clause. ... But these interests will be generally limited to freedom from restraint which, while not exceeding the sentence in such an unexpected manner as to give rise to protection by the Due Process Clause of its own force, ... nonetheless imposes atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life. Sandin, 515 U.S. at 483-484.