Wilkinson v. Austin
Headline: Court upholds Ohio’s revised procedures for placing inmates in extreme Supermax isolation, recognizing prisoners’ liberty interest while allowing the state to keep strict security controls.
Holding: The Court held that Ohio’s new classification procedures provide sufficient procedural protection under the Due Process Clause for placement in its Supermax facility, while recognizing inmates have a liberty interest in avoiding such placement.
- Requires notice and chance to rebut before Supermax placement.
- Allows Ohio to keep strict security controls while using informal multi-step reviews.
- Permits future challenges if the policy is not followed in practice.
Summary
Background
A group of current and former inmates challenged how Ohio assigned people to its Supermax prison, the Ohio State Penitentiary (OSP). OSP confines prisoners in extreme isolation, with almost no human contact, single cells, limited exercise, and indefinite stays that also suspend parole eligibility. Ohio had an earlier, inconsistent practice and then issued a written “New Policy” to guide placement and give inmates notice and reviews. The inmates sued under federal law claiming the earlier system and the New Policy denied them fair process.
Reasoning
The Court first asked whether inmates have a protected interest in avoiding placement at OSP. Applying the Sandin test, it found the combination of severe isolation, indefinite duration, and loss of parole rights is an "atypical and significant" hardship. The Court then used the Mathews balancing test to decide what process is due. It held Ohio’s New Policy gives key protections: written notice of the factual basis, an opportunity to be heard and rebut evidence, a three-step review process with powers to overturn recommendations, and a 30-day follow-up review. Balancing those protections against safety and administrative burdens, the Court concluded the New Policy’s informal, nonadversary procedures are adequate and that the District Court should not have imposed additional procedural requirements.
Real world impact
The ruling means inmates facing transfer to OSP must receive the New Policy’s notice, hearing, and multi-level review protections. States may continue strict Supermax security practices while using informal procedures rather than full adversary hearings. If Ohio’s procedures fail in practice, inmates may bring future challenges asking courts to correct violations.
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