Superintendent, Mass. Correctional Institution at Walpole v. Hill

Supreme Court of the United States
472 U.S. 445, 86 L. Ed. 2d 356, 1985 U.S. LEXIS 109 (1985)

ELI5:

Rule of Law:

To comport with the Due Process Clause of the Fourteenth Amendment, a prison disciplinary board's decision to revoke an inmate's good time credits must be supported by some evidence in the record.

Facts:

Respondents Gerald Hill and Joseph Crawford were inmates at a Massachusetts state prison.
A prison guard, Sergeant Maguire, heard a commotion coming from a prison walkway.
Upon investigating, Maguire found inmate Stephens bleeding from the mouth and with a swollen eye.
Maguire saw three inmates, including Hill and Crawford, jogging away together down the enclosed walkway.
There were no other inmates present in the area.
Stephens later provided written statements that Hill and Crawford had not caused his injuries.
Both Hill and Crawford declared their innocence to the disciplinary board.

Procedural Posture:

A prison disciplinary board found inmates Gerald Hill and Joseph Crawford guilty of assault and recommended the loss of 100 days of good time credits.
The inmates unsuccessfully appealed the board’s action to the superintendent of the prison.
Hill and Crawford filed a complaint in the Massachusetts Superior Court (a state trial court), alleging the decision was not supported by any evidence.
The Superior Court granted summary judgment for the inmates, voided the board's findings, and ordered the good time restored.
The prison Superintendent (petitioner) appealed to the Massachusetts Supreme Judicial Court (the state's highest court).
The Massachusetts Supreme Judicial Court affirmed the Superior Court's judgment, finding the record lacked 'some evidence' to support the board's decision.
The Superintendent successfully petitioned the U.S. Supreme Court for a writ of certiorari.

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Issue:

Does the Due Process Clause of the Fourteenth Amendment require that a prison disciplinary board's decision to revoke an inmate's good time credits be supported by some evidence in the record?

Opinions:

Majority - Justice O’Connor

Yes. Revocation of good time credits does not comport with the minimum requirements of procedural due process unless the findings of the prison disciplinary board are supported by some evidence in the record. The Court balanced the inmate's liberty interest in good time credits against the institutional needs of the prison, such as safety and discipline. It concluded that requiring a 'modicum of evidence' prevents arbitrary deprivations of liberty without imposing undue administrative burdens on prison officials. This 'some evidence' standard is not a high bar; it does not require a court to examine the entire record, assess witness credibility, or weigh the evidence. The relevant question is simply whether there is any evidence that could support the board's conclusion. Applying this standard, the Court found that the guard's testimony about finding an injured inmate and seeing only the respondents jogging away from the enclosed area was sufficient to constitute 'some evidence,' even though it was circumstantial and contradicted by the victim and the accused.

Concurring in part and dissenting in part - Justice Stevens

Yes. Justice Stevens agreed with the majority's adoption of the 'some evidence' standard but dissented from its decision to apply that standard and reverse the state court. He argued that the Court should never have heard the case because the primary question presented—whether due process requires judicial review—was moot, as Massachusetts state law already provided such review. Stevens criticized the Massachusetts Attorney General for failing to disclose this to the Court in the petition for certiorari. He contended that by proceeding to review the sufficiency of the evidence itself, the Court was overstepping its role and acting as a court of error correction for a fact-bound state case, rather than adhering to principles of judicial restraint.

Analysis:

This decision establishes the constitutional minimum evidentiary standard for prison disciplinary proceedings that result in the loss of a liberty interest, such as good time credits. By setting the bar at 'some evidence,' the Court grants significant deference to prison administrators, reinforcing that prison disciplinary hearings are not criminal trials and do not require the same level of proof. This standard ensures that decisions are not completely arbitrary but makes it very difficult for inmates to successfully challenge disciplinary findings in federal court. The case solidifies the principle from Wolff v. McDonnell that while prisoners retain due process rights, those rights are substantially limited by the unique security and administrative needs of the prison environment.

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