Sandin v. Conner - Essay Example

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In August 1987, Conner, an inmate at the Halawa Correctional Facility in Oahu, was subjected to a strip search, to which he angrily retorted with foul language at the officer. Conner was thereafter brought before an adjustment committee on charges of serious misconduct, during…
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Sandin v. Conner
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SANDIN, Unit Team Manager, Halawa Correctional Facility v. CONNER et al. 515 U.S. 472 Certiorari to the Unites s Court of Appeals for the Ninth Circuit
Facts of the Case
In August 1987, Conner, an inmate at the Halawa Correctional Facility in Oahu, was subjected to a strip search, to which he angrily retorted with foul language at the officer. Conner was thereafter brought before an adjustment committee on charges of serious misconduct, during which proceedings he was not allowed to call witnesses to testify on his behalf. The committee thereafter found him guilty of the charge and penalized him with thirty days in disciplinary segregation. Aggrieved, Conner brought action against Sandin and other prison officials for allegedly depriving him of procedural due process.
Procedural History
In said action, the District Court granted the officials summary judgement, which was however reversed by the Court of Appeals. The CA ruled that Conner had a liberty interest to be free from disciplinary segregation, for which reason there was a question of fact whether he had been denied due process, under Wolff v. McDonnell (418 US 539).
Issue: Whether or not Conner is entitled to all of due process based on protected liberty interest
Holding: NO, Conner is not entitled to protected liberty interest.
1. According to the decision in Wolff, states may in certain circumstances create liberty interests that are protected by the Due Process Clause. Those interests, however, will mostly be in the nature of freedom from restraint, in the sense that the punishment imposes an atypical and significant hardship on the inmate in relation to the ordinary and usual conditions of prison life.
2. Conner is incorrect in asserting that any state action taken for a punitive reason violates a liberty interest under the Due Process Clause even in the absence of any state regulation.
3. The punitive measure taken against Conner, which is disciplinary segregation, is not the atypical, significant hardship in which a State might conceivably create a liberty interest. Aside from the fact that Conner’s record was subsequently expunged, segregation was administered as a usual condition of prison life, not more burdensome than similar measures imposed upon inmates in administrative segregation and protective custody. Conner’s discipline did not exceed similar but totally discretionary confinement, in either duration or degree of restriction.
The High Court ruled that Conner’s situation does not entitle him to all the procedures required in due process on the basis of protected liberty interest. CA decision is reversed.
Agree or Disagree
This writer agrees with the decision. It is true that prisoners do not shed all constitutional rights at the prison gate, (Wolff, 418 U.S. at 555), but it must be remembered that “lawful incarceration brings about the necessary withdrawal or limitation of many privileges and rights, a retraction justified by the considerations underlying our penal system” (Price v. Johnston, 334 U.S. 266, 285 (1948)). The court has determined that while the case involves a punitive measure imposed on Conner, it is not a “dramatic departure” from the basic conditions of his sentence. Within bounds of reason and where abuse is absent, the administration of our penal system should not be unduly shackled where the Due Process Clause confers no liberty interest.
ACLU, “Sandin v. Conner”, 30 June 2009, 15 July 2009, Blum, Karen M., “Note on Sandin v. Conner”, Basic Principles of Section 1983 Litigation,, Suffolk University Law School, 1 February 2006, p. 164
Lynch vs. Whitman, CA 03-162ML, U.S. District Court for the District of Rhode Island
Price v. Johnston, 334 U.S. 266 (1948)
Sandin v. Conner et al., 515 U.S. 472 (1995)
Wolff v. McDonnell, 418 US 539 (1974) Read More
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