Sandin v. Conner
Headline: Ruling limits prisoners’ constitutional protection for disciplinary segregation, reversing the appeals court and holding 30-day segregation did not create a protected liberty interest, making it harder for inmates to win due process claims.
Holding: The Court held that Conner’s 30-day segregated punishment did not impose an atypical, significant hardship and therefore did not create a Fourteenth Amendment liberty interest giving him entitlement to extra disciplinary procedures.
- Makes it harder for inmates to claim due process for routine disciplinary segregation.
- Gives prisons more leeway in disciplining inmates without extra procedures.
- Reduces incentives for states to adopt detailed prison rules that create rights.
Summary
Background
DeMont Conner is a prisoner in a maximum-security Hawaii prison who reacted angrily during a strip search. He was charged with obstructing an officer, using abusive language, and harassing staff. At his adjustment committee hearing the committee refused his request to call staff witnesses, relied on Conner’s own statements and written reports, found him guilty, and sentenced him to 30 days in segregated confinement; an administrative review later expunged the obstruction conviction.
Reasoning
The central question was whether that 30-day disciplinary segregation deprived Conner of a liberty interest protected by the Fourteenth Amendment so that he was entitled to extra procedural protections. The Court adopted a standard requiring an “atypical and significant hardship” relative to ordinary prison life. The majority concluded Conner’s confinement closely resembled administrative segregation and protective custody, was not unusually harsh for his indeterminate sentence, and was later expunged, so it did not create a protected liberty interest. The Court therefore reversed the Ninth Circuit and held no entitlement to the special procedures the appeals court had required.
Real world impact
The decision narrows when prisoners may claim constitutional due process for disciplinary segregation by focusing on whether the punishment is genuinely atypical and significant. It also signals more deference to prison administrators in routine discipline and reduces the reach of procedural protections that hinged on mandatory language in prison rules.
Dissents or concurrances
Justices Ginsburg and Breyer (joined by others) dissented: they argued the segregation was a serious, liberty-depriving change that can stigmatize inmates and affect parole, and they would have found a protected liberty interest and required a focused review of whether Conner got adequate process.
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