The Legality of Disciplinary Segregation in Prison
In Sandin v. Conner, 515 U.S. 472 (1995), a prisoner brought a civil rights action against prison officials and the State of Hawaii, challenging the imposition of disciplinary segregation for misconduct.
The Court in Sandin determined that a state-created liberty interest could arise only when a prison's action imposed an "atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life." Id. at 484.
The Court went on to point out that the punishment of incarcerated prisoners serves the aim of effectuating prison management and prisoner rehabilitative goals and that discipline by prison officials in response to misconduct is within the expected parameters of the prisoner's sentence.
The Court found that the prisoner's placement in segregated confinement did not present the type of atypical, significant deprivation in which a State might conceivably create a liberty interest.
The Sandin Court considered the following factors:
(1) the amount of time the prisoner spent in disciplinary segregation;
(2) whether the conditions of his confinement in disciplinary segregation were significantly more restrictive than those imposed upon other inmates in solitary confinement;
(3) whether the State's action would affect the duration of the inmate's sentence.
The Court held that the prisoner's confinement in administrative segregation did not by itself implicate a protected liberty interest because the duration and degree of restriction did not exceed similar, but totally discretionary, confinement.
The Court specifically pointed out that the conditions in disciplinary segregation in Hawaii "mirrored those conditions imposed upon inmates in administrative segregation and protective custody." Id. at 486.
The Court also observed that the duration of the prisoner's sentence was not affected by the confinement, as the chance that the misconduct finding would affect a later parole decision was too attenuated.