Wolff v. McDonnell

Last updated
Wolff v. McDonnell
Seal of the United States Supreme Court.svg
Argued April 22, 1974
Decided June 26, 1974
Full case nameWolff, Warden, et al. v. McDonnell
Docket no. 73-679
Citations418 U.S. 539 ( more )
94 S. Ct. 2963; 41 L. Ed. 2d 935; 1974 U.S. LEXIS 91
Case history
PriorJudgment for plaintiffs in part, 342 F. Supp. 616 (D. Neb. 1972); aff'd in part, 483 F. 2d 1059 (8th Cir. 1973); cert. granted, 414 U.S. 1156 (1974).
Holding
In administrative proceedings regarding discipline, prisoners retain some of their due process rights.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William O. Douglas  · William J. Brennan Jr.
Potter Stewart  · Byron White
Thurgood Marshall  · Harry Blackmun
Lewis F. Powell Jr.  · William Rehnquist
Case opinions
MajorityWhite, joined by Burger, Stewart, Blackmun, Powell, Rehnquist
Concur/dissentMarshall, joined by Brennan
Concur/dissentDouglas
Laws applied
U.S. Const. amend. XIV

Wolff v. McDonnell, 418 U.S. 539 (1974), was a United States Supreme Court case in which the Court held that prisoners retained some due process rights when incarcerated. In particular, the Court ruled that due process required that prison disciplinary decisions to revoke good-time credits must be accompanied by notification of the inmate, administrative hearings, the chance to call witnesses and present evidence, and a written statement detailing the nature of the offense committed and the evidence for said offense.

Prison place in which people legally are physically confined and usually deprived of a range of personal freedoms

A prison, also known as a correctional facility, jail, gaol, penitentiary, detention center, correctional center, or remand center, is a facility in which inmates are forcibly confined and denied a variety of freedoms under the authority of the state. Prisons are most commonly used within a criminal justice system: people charged with crimes may be imprisoned until their trial; those pleading or being found guilty of crimes at trial may be sentenced to a specified period of imprisonment. In simplest terms, a prison can also be described as a building in which people are legally held as a punishment for a crime they have committed.

Contents

Background

In 1974, Robert O. McDonnell, an inmate at the Nebraska Penal and Correctional Complex, filed a class action lawsuit against Warden Charles Wolff Jr., charging, among other complaints, that the disciplinary proceedings hearings at the prison were biased and violated due process, that the inspection of all incoming and outbound mail (including mail to and from attorneys) was unreasonable, and that the legal assistance available to inmates was lacking. At the time, the process for disciplinary proceedings involved the prisoner being orally informed of the nature of the charges against them, a report being written by a committee, and the report being read to the inmate. If the inmate denied the charge, they could inquire as to the charging party, but could not cross-examine or present any witnesses. Penalties imposed by the hearings could include loss of good-time credits. [1]

The Nebraska State Penitentiary (NSP) is a state correctional facility for the Nebraska Department of Correctional Services. Located in Lincoln, it is the oldest state correctional facility in Nebraska, opening in 1869. Until after World War I, it was the only adult correctional facility in the state.

A class action, also known as a class action lawsuit, class suit, or representative action, is a type of lawsuit where one of the parties is a group of people who are represented collectively by a member of that group. The class action originated in the United States and is still predominantly a U.S. phenomenon, but Canada, as well as several European countries with civil law have made changes in recent years to allow consumer organizations to bring claims on behalf of consumers.

Due process is the legal requirement that the state must respect all legal rights that are owed to a person. Due process balances the power of law of the land and protects the individual person from it. When a government harms a person without following the exact course of the law, this constitutes a due process violation, which offends the rule of law.

The district court granted only partial relief: it rejected the due process claim, and stated that the legal assistance was not unconstitutionally defective, but found the inspection of mail to violate the right of access to the courts.

United States District Court for the District of Nebraska

The United States District Court for the District of Nebraska is the Federal district court whose jurisdiction is the state of Nebraska. Court offices are in Omaha and Lincoln.

The Eighth Circuit reversed the district court on the due process claim, affirmed the judgment regarding mail, and ordered hearings into the quality of legal assistance.

United States Court of Appeals for the Eighth Circuit

The United States Court of Appeals for the Eighth Circuit is a United States federal court with appellate jurisdiction over the following United States district courts:

Robert Bork, in his capacity as Solicitor General of the United States, argued as amicus curiae , urging reversal of the judgment of the circuit court.

Robert Bork 35th Solicitor General of the United States

Robert Heron Bork was an American judge, government official and legal scholar who served as the Solicitor General of the United States from 1973 to 1977. A professor at Yale Law School by occupation, he later served as a judge on the influential U.S. Court of Appeals for the D.C. Circuit from 1982 to 1988. In 1987, President Ronald Reagan nominated Bork to the U.S. Supreme Court, but the U.S. Senate rejected his nomination.

Solicitor General of the United States

The Solicitor General of the United States is the fourth-highest-ranking official in the United States Department of Justice. The current Solicitor General, Noel Francisco, took office on September 19, 2017.

An amicus curiae is someone who is not a party to a case and may or may not have been solicited by a party and who assists a court by offering information, expertise, or insight that has a bearing on the issues in the case; and is typically presented in the form of a brief. The decision on whether to consider an amicus brief lies within the discretion of the court. The phrase amicus curiae is legal Latin.

Opinion of the Court

In the majority opinion authored by Justice White, the Court rejected the idea that prisoners were wholly deprived of their rights under the Constitution. Nevertheless, the majority opinion also recognized that reasonable constraints were, given the nature of imprisonment, not restrictive, especially when pertaining to issues of due process:

Prison disciplinary proceedings are not part of a criminal prosecution, and the full panoply of rights due a defendant in such proceedings does not apply.

The Court went on to note that prisoners were entitled to written notice of violations, at least a day in advance of any hearing, and a written statement from the committee regarding the evidence used and the reasons for a disciplinary hearing. So long as the acts were not "unduly hazardous to institutional safety or correctional goals", the prisoner could also call witnesses and present evidence in their defense, the Court ruled; the unrestricted right to do so would disrupt the authority of prison officials to provide for the safety of others. Likewise, allowing cross-examination would heighten the potential for disruption and danger; and allowing counsel would cause delay and reduce the utility of the proceedings.

The Court declined to rule on the impartiality of the committee, noting its mandate and the regulations that controlled it.

As for the question of searching the mail, the Court ruled that it had no issue with states requiring attorneys to specially mark their mail, with name and address; and said that opening mail in the presence of inmates did not constitute censorship.

The Court affirmed the Eighth Circuit on the issue of insufficient inmate legal assistance, and remanded the case for further judgment.

Marshall's opinion

Justice Marshall, joined by Brennan, agreed on the issues of mail inspection and legal assistance, but disagreed with the majority on the matter of due process. In Marshall's view, inmates did not lose their rights by entering prison, and, in accordance with that, believed that the lack of confrontation and cross-examination in the majority opinion was the Court denying basic constitutional rights to inmates.

Douglas's opinion

Justice Douglas believed the entirety of a "full hearing with all due process safeguards" was needed before punishments such as solitary confinement could be imposed.

Solitary confinement Strict imprisonment form

Solitary confinement is a form of imprisonment distinguished by living in single cells with little or no meaningful contact to other inmates, strict measures to control contraband, and the use of additional security measures and equipment. It is specifically designed for disruptive inmates who are security risks to other inmates, the prison staff, or the prison itself. It is mostly employed for violations of discipline, such as murder, hostage-taking, deadly assault, and rioting. However, it is also used as a measure of protection for inmates whose safety is threatened by other inmates.

See also

Related Research Articles

Contempt of court, often referred to simply as "contempt", is the offense of being disobedient to or disrespectful toward a court of law and its officers in the form of behavior that opposes or defies the authority, justice and dignity of the court. A similar attitude towards a legislative body is termed contempt of Parliament or contempt of Congress.

<i>Harvey v. Horan</i>

Harvey v. Horan, 278 F. 3d 370 is a federal court case dealing with felons' rights of access to DNA testing. The Eastern Virginia District Court originally found that felons were entitled access to DNA testing on potentially exculpatory evidence, but this finding was later overturned by the Fourth Circuit Court of Appeals. Nevertheless, the case paved the way for the Innocence Protection Act, which ensures that convicted offenders can try to prove their innocence by requesting DNA testing on evidence in government's possession that was used in their case.

Due Process Clause Clauses in the 5th and 14th Amendments to the U.S. Constitution

The Fifth and Fourteenth Amendments to the United States Constitution each contain a due process clause. Due process deals with the administration of justice and thus the due process clause acts as a safeguard from arbitrary denial of life, liberty, or property by the government outside the sanction of law. The Supreme Court of the United States interprets the clauses broadly, concluding that these clauses provide four protections: procedural due process, substantive due process, a prohibition against vague laws, and as the vehicle for the incorporation of the Bill of Rights.

Guantanamo military commission U.S. military tribunals

The Guantanamo military commissions are military tribunals authorized by presidential order, then by the Military Commissions Act of 2006, and currently by the Military Commissions Act of 2009 for prosecuting detainees held in the United States Guantanamo Bay detainment camps.

Strickland v. Washington, 466 U.S. 668 (1984), was a landmark Supreme Court case that established the standard for determining when a criminal defendant's Sixth Amendment right to counsel is violated by that counsel's inadequate performance.

Greenholtz v. Inmates of the Nebraska Penal and Correctional Complex, 442 U.S. 1 (1979), was a United States Supreme Court case in which the Court held that when state law requires the state to grant parole whenever a prisoner satisfies certain conditions, due process requires the state to allow the prisoner to present evidence in support of his request for parole and to furnish a written explanation of the reasons why his request has been denied.

Superintendent v. Hill, 472 U.S. 445 (1985), was a United States Supreme Court case in which the Court held that due process required that prison disciplinary decisions to revoke good-time credits must be supported by "some evidence."

Cleveland Board of Education v. Loudermill, 470 U.S. 532 (1985), was a United States Supreme Court case in which the Court held that:

Nutraloaf is a food served in prisons in the United States and Canada to inmates who have misbehaved; for example, assaulting prison guards or fellow prisoners. It is similar to meatloaf in texture, but has a wider variety of ingredients. Prison loaf is usually bland, perhaps even unpleasant, but prison wardens argue that nutraloaf provides enough nutrition to keep prisoners healthy without requiring utensils to be issued.

Prison Legal News (PLN) is a monthly American magazine and online periodical published since May 1990. It primarily reports on criminal justice issues and prison and jail-related civil litigation, mainly in the United States. It is a project of the Human Rights Defense Center (HRDC), a 501(c)(3) non-profit organization.

LGBT people in prison

Lesbian, gay, bisexual, and transgender (LGBT) prisoners often face additional challenges compared to non-LGBT prisoners. According to Just Detention International, LGBT inmates are "among the most vulnerable in the prison population". 67% of LGBT prisoners in California report being assaulted while in prison. The vulnerability of LGBT prisoners has led some prisons to separate them from other prisoners, while in others they are housed with the general population.

Marsy's Law, the California Victims' Bill of Rights Act of 2008, enacted by voters as Proposition 9 through the initiative process in the November 2008 general election, is an Amendment to the state's constitution and certain penal code sections. The act protects and expands the legal rights of victims of crime to include 17 rights in the judicial process, including the right to legal standing, protection from the defendant, notification of all court proceedings, and restitution, as well as granting parole boards far greater powers to deny inmates parole. Passage of this law in California has led to the passage of similar laws in Florida, Georgia, Illinois, Kentucky, Nevada, North Carolina, Oklahoma, and Ohio, and efforts to pass similar laws in Wisconsin, Hawaii, Iowa, Montana, Idaho, and South Dakota. In November 2017, Marsy's Law was found to be unconstitutional and void in its entirety by the Supreme Court of Montana for violating that State's procedure for amending the Montana Constitution.

Bounds v. Smith, 430 U.S. 817 (1977), was a United States Supreme Court case in which the Court tested the basic constitutional right of prison inmates’ access to legal documents prior to court. Prison authorities would consequently be required to provide legal assistance and counsel to inmates, whether it be through a trained legal professional or access to a legal library. Multiple prisoners alleged that they were denied access to the courts due to lack of an adequate legal library and assistance with court related documents.

Holt v. Hobbs, 574 U.S. ___ (2015), was an American legal case in which the Supreme Court unanimously ruled that an Arkansas prison policy which prohibited a Muslim prisoner from growing a short beard in accordance with his religious beliefs violated the Religious Land Use and Institutionalized Persons Act (RLUIPA).

In re Oliver, 333 U.S. 257 (1948), was a decision by the United States Supreme Court involving the application of the right of due process in state court proceedings. The Sixth Amendment in the Bill of Rights states that criminal prosecutions require the defendant "... to be informed of the nature and cause of the accusation...and to have the Assistance of Counsel for his defence." In this case, a witness in a Michigan grand jury hearing was convicted and sentenced to jail without either notice or attorney assistance.

Human Rights Defense Center is a non-profit 501(c)(3) organization that campaigns on behalf of prisoner rights across the United States. The organization advocates for the rights of people in "state and federal prisons, local jails, immigration detention centers, civil commitment facilities, Bureau of Indian Affairs jails, juvenile facilities and military prisons." Some of the major focuses of the Human Rights Defense Center (HRDC) include work on free speech issues, government transparency and accountability, as well as opposition to the private prison industry.

August Rebellion

The August Rebellion refers to a 1974 riot at the Bedford Hills Correctional Facility for Women, a prison in Bedford Hills in the Town of Bedford, Westchester County, New York, United States. In August 1974, about 200 of these prisoners rioted, taking over parts of the prison, because of the inhumane treatment of one of the leaders among the prisoners, Carol Crooks.

Prisoner Law refers to litigation that determines the freedoms that a prisoner either holds or loses when they are incarcerated. This includes the end of the Hands- Off Doctrine and the ability to be protected by the First, Fourth, Eighth, and Fourteenth Amendments. Furthermore, prisoner laws regulate the ways in which individuals experience privacy in a prison setting. Important case laws have arisen through time that have either hindered or protected prisoners from certain rights. Some include the Hudson v. Palmer case which held that prisoners were not protected against searches and seizures of their prison cells and Wolff v. McDonnell that stated that prisoners shall remain entitled to some of their constitutional rights even after being incarcerated.

Hudson v. Palmer, 468 U.S. 517 (1984), is a United States Supreme Court case in which the Court held that prison inmates have no privacy rights in their cells protected by the Fourth Amendment to the United States Constitution. The Court also held that an intentional deprivation of property by a state employee "does not violate the Fourteenth Amendment if an adequate postdeprivation state remedy exists," extending Parratt v. Taylor to intentional torts.

References

  1. "Due Process: Wolff v. McDonnell, 418 U.S. 539 (1974)". Journal of Criminal Law & Criminology . 65 (4): 476–82. 1974.