In Morrissey v. Brewer, 408 U.S. 471 (1972) the United States Supreme Court set forth the minimal due process requirements that a parole revocation hearing must meet to satisfy the Fourteenth Amendment to the United States Constitution. Those requirements include: (a) written notice of the claimed violations of parole; (b) disclosure to the parolee of evidence against him; (c) opportunity to be heard in person and to present witnesses and documentary evidence; (d) the right to confront and cross-examine adverse witnesses (unless the hearing officer specifically finds good cause for not allowing confrontation); (e) a "neutral and detached" hearing body such as a traditional parole board, members of which need not be judicial officers or lawyers; and (f) a written statement by the factfinders as to the evidence relied on and reasons for revoking parole. Morrissey, 408 U.S. at 489. The United States Supreme Court established the minimum due process requirements for persons arrested for parole violations. The Court mandated a two-step process for the disposition of parole violation charges. The first step is a hearing to determine "whether there is probable cause or reasonable ground to believe that the arrested parolee has committed acts that would constitute a violation of parole conditions." Id. at 485. This "minimal" inquiry, which is in the nature of a preliminary hearing, is to be "conducted at or reasonably near the place of the alleged parole violation or arrest and as promptly as convenient after arrest." Id. The parolee must be given notice of this hearing and an opportunity to appear, speak on his own behalf, and present documentary evidence or individuals who can give relevant information to the hearing officer. The parolee may also request that persons who have given the adverse information upon which the revocation proceeding is based be made available for questioning in the parolee's presence. Id. at 487. A finding of probable cause by a neutral hearing officer at the conclusion of this preliminary hearing will justify the parolee's continued detention. If probable cause is found, the second step mandated by Morrissey is a final hearing for the evaluation of contested evidence, a determination whether the alleged violation occurred, and, if so, a determination whether revocation of the parole is appropriate. 408 U.S. at 488. In Morrissey v. Brewer (1972) 408 U.S. 471, the court began its consideration of the issues before it by noting that parole revocation "deprives an individual, not of the absolute liberty to which every citizen is entitled, but only of the conditional liberty properly dependent on observance of special parole restrictions." (Morrissey, supra, 408 U.S. at p. 480.) The question was whether this conditional liberty interest fell within the contemplation of the "liberty or property" language of the Fourteenth Amendment to the United States Constitution. The test as to "whether any procedural protections are due," according to the Supreme Court, "depends on the extent to which an individual will be 'condemned to suffer grievous loss of liberty.' " (Morrissey, at p. 481.) Because a parolee's conditional liberty "includes many of the core values of unqualified liberty and its termination inflicts a 'grievous loss' on the parolee," the court held that a parolee's conditional liberty comes within the protections of the Fourteenth Amendment and cannot be revoked without due process. (Morrissey, at p. 482.) "Turning to the question what process is due" (Morrissey, supra, 408 U.S. at p. 483), the court declared that in light of the conditional nature of a parolee's liberty it would not extend the same procedural protections to parole violators as to criminal defendants. "We begin with the proposition that the revocation of parole is not part of a criminal prosecution and thus the full panoply of rights due a defendant in such a proceeding does not apply to parole revocations." (Id. at p. 480.) What is needed," the court concluded, "is an informal hearing structured to assure that the finding of a parole violation will be based on verified facts and that the exercise of discretion will be informed by an accurate knowledge of the parolee's behavior." (Id. at p. 484.) The court declined to identify specific procedures for revoking parole, leaving to the individual states the task of devising parole revocation procedures. (Id. at p. 488.) Morrissey v. Brewer, makes it clear that the benefits that inure as a result of that liberty interest cannot be taken away without the parolee's being informed of the alleged parole violation and being given a hearing at which he can rebut the allegations. "The parolee must have an opportunity to be heard and to show, if he can, that he did not violate the conditions, or, if he did, that circumstances in mitigation suggest that the violation does not warrant revocation. " Id., 488. The Supreme Court held that the constitutional guarantee of due process requires a two-step hearing process prior to the revocation of parole. The first step is a minimal inquiry, "in the nature of a 'preliminary hearing.'" Id. It must be conducted at or reasonably near the place of the alleged violation and as promptly as reasonably convenient to determine whether there is probable cause to believe there has been a parole violation. Id. This determination must be made by a neutral official who is uninvolved in the parolee's case; i.e., someone other than the parole officer who reported the alleged violations or recommended revocation. Id. at 485-86. The parolee has the right to notice of this hearing and of the nature of the violations that are alleged. The parolee also is entitled to appear and speak in his or her own behalf and to bring letters, other documents, or individuals who can give evidence to the hearing officer. Id. at 487. On the parolee's request, the source of adverse information upon which the violation report is based must be made available for questioning in the parolee's presence. Id. The second step in the procedure mandated by Morrissey is a more extensive final hearing to determine whether a violation has occurred and, if so, whether the parole should be revoked. At this hearing, the parolee must have an opportunity to be heard and to present evidence that the conditions of parole were not violated or that mitigating circumstances weigh against revocation. Id. at 487-88. This hearing is not the equivalent of a trial, but it does carry some of the same procedural safeguards, such as the right to confront adverse witnesses. Id. at 489. The United States Supreme Court held that a parolee is not entitled to the full panoply of due process rights, because parole revocation is not part of a criminal prosecution and because revocation deprives a parolee of conditional liberty, not absolute liberty; nevertheless, the high court held that a parolee who has been detained for a parole violation is entitled to an informal probable cause hearing and a final revocation hearing. (Id. at pp. 480, 485, 487.)