Sandin v. Conner

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515 U.S. 472 (1995), argued 28 Feb. 1995, decided 19 June 1995 by vote of 5 to 4; Rehnquist for the Court, Ginsburg in dissent, joined by Stevens, Breyer in dissent, joined by Souter. Sandin marked a sharp move by the Court away from its holdings in several earlier prisoner rights cases and made it more difficult for prisoners to bring lawsuits challenging on constitutional grounds the management of prisons.

DeMont R. D. Conner, a convicted murderer serving thirty years to life in Hawaii's maximum security correctional facility, brought suit against Cinda Sandin, a manager in the prison. Conner claimed that Sandin had refused to allow him to call witnesses before being subjected to disciplinary segregation for breaking prison rules, a punishment that placed him in solitary confinement for thirty days. Conner insisted that Sandin's failure to do so amounted to a violation of procedural due process under the Fourteenth Amendment to the Constitution. At issue in the case was the extent to which prison rules dealing with such matters had established a “liberty interest” to be protected under the amendment. The Court had previously recognized that such due process rights as a hearing and the ability to call witnesses came into play when the state's actions had clearly violated a substantive right of the prisoner. For example, if an inmate had behaved well and “earned” time that would shorten his sentence, then he could not be deprived of this substantial right without a hearing. During the 1980s, however, the Court had created considerable uncertainty through its case law about what constituted a substantial and a trivial protection and prompted a flood of litigation by inmates such as Conner.

Chief Justice William H. Rehnquist's goal was to bring clarity to the issue. He concluded that the Court had become far too lenient in accepting assertions by prisoners that their rights had been violated. So-called jailhouse lawyers would comb prison regulations seeking instances of even the smallest procedural violations and then invoke them to charge that prison authorities had denied a liberty interest. The chief justice articulated a standard that required a prisoner to demonstrate that authorities had imposed an atypical and significant hardship rather than carrying out the routine, day-to-day business of the prison. Being placed in solitary confinement at a maximum security prison did not meet this new standard, and the Court rejected Conner's claim. Rehnquist's decision left in place, however, another constitutional provision under the Eighth Amendment that prevents jailers from administering cruel and unusual punishment.

The dissenters also recognized that Conner presented a weak case, and Justice Stephen Breyer went so far as to argue in his dissenting opinion that the inmate did not deserve relief. Yet the dissenters also insisted that Rehnquist's opinion was far too broad and left lower federal courts with little discretion in separating the unimportant complaints brought forward by prisoners from the significant ones. The dissenters also recognized that Rehnquist's opinion fitted neatly with his main objective of curbing prisoners’ lawsuits generally.


Subjects: Law.

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