Supreme Court of the United States
Superintendent, Massachusetts Correctional Institution at Walpole v. Hill
June 17, 1985472 U.S. 445
Summary
The Court held that revocation of prison good-time credits satisfies due process if supported by some evidence in the record. It declined to decide whether the Constitution independently requires judicial review because state law supplied a mechanism for reviewing the disciplinary decision. Applying the some-evidence standard, the Court found sufficient evidence linking the inmates to the assault and reversed and remanded.
Holding
- Whether due process requires judicial review of a prison disciplinary decision revoking good-time credits. The Court declined to decide whether the Due Process Clause independently requires judicial review because state law provided a mechanism for reviewing the inmates' claims.
- What evidentiary showing due process requires before good-time credits may be revoked, and whether the record satisfied that requirement. Due process is satisfied when some evidence in the record supports a prison disciplinary board's decision to revoke good-time credits. The evidence here, although meager and circumstantial, was sufficient because it provided a factual basis for finding that the respondents participated in the assault.
Docket 84-438
Cited authorities
- Rule 34.1(g)
- Rule 35.5
- CA11
- 66 Harv. L. Rev. 1362