Supreme Court of the United States
Olim v. Wakinekona
April 26, 1983461 U.S. 238
Summary
The Court held that transferring a state prisoner from Hawaii to California did not itself implicate a liberty interest protected by the Fourteenth Amendment. It further held that Hawaii's prison regulations did not create such an interest because they imposed no substantive limits on the administrator's discretion, notwithstanding their mandatory hearing procedures. The Court therefore reversed the Ninth Circuit's judgment.
Holding
- Whether an interstate prison transfer directly implicates a liberty interest protected by the Due Process Clause.. An interstate transfer of a convicted prisoner, including a transfer from Hawaii to California, does not by itself deprive the prisoner of a liberty interest protected by the Due Process Clause.
- Whether Hawaii's prison regulations create a protected liberty interest through their substantive standards and procedural requirements.. Hawaii's regulations do not create a protected liberty interest because they impose no substantive limitations on the administrator's discretion to transfer a prisoner; mandatory procedures alone do not create an independent constitutional entitlement to remain in a particular prison.
Docket 81-1581
Cited authorities
- Idaho Code § 20-701
- 42 U.S.C. § 1983
- 18 U.S.C. § 5003
- 18 U.S.C. § 4002
- Haw. Rev. Stat. § 353-18
- Alaska Stat. Ann. § 33.30.100
- Haw. Rev. Stat. § 355-1
- 71 Calif. L. Rev. 146