In Vitek v. Jones, 445 U.S. 480 (1980), the Supreme Court considered an inmate-patient's procedural due process challenge to Nebraska's analogue to Correction Law 402(1). The Vitek Court concluded that the transfer of an inmate from a correctional facility to a civil psychiatric hospital implicates a liberty interest, and cannot be undertaken without affording the inmate due process protections, which included, at a minimum, written notice that psychiatric hospitalization was being considered; a hearing at which the inmate could present evidence opposing the transfer; an independent decision-maker; and the assistance of competent help at the hearing, though not necessarily by an attorney, among others. (Id., at 494-497.) In Vitek, the Supreme Court ruled that a criminal conviction and sentence of imprisonment do not authorize the State to classify an inmate as mentally ill and subject him to involuntary psychiatric treatment without affording him certain due process protections such as prior written notice and a hearing before an independent decision maker. In Vitek v. Jones, the Supreme Court held that, absent a determination in a civil commitment proceeding of current mental illness and dangerousness, even an incarcerated prisoner serving a criminal sentence could not be transferred to a mental institution. There, the Supreme Court noted that even a convicted felon serving his criminal sentence has a liberty interest, which is not extinguished by his criminal confinement, in not being transferred to a mental institution and thus classified as mentally ill. (445 US at 493.) The Court held that "the loss of liberty produced by an involuntary commitment is more than a loss of freedom from confinement." (Id. at 492.)