Hewitt v. Helms
Annotate this Case
459 U.S. 460 (1983)
U.S. Supreme Court
Hewitt v. Helms, 459 U.S. 460 (1983)
Hewitt v. Helms
Argued November 8, 1982
Decided February 22, 1983
459 U.S. 460
Following a riot in the Pennsylvania State Prison where he was an inmate, respondent was removed from his cell and the general prison population and confined to administrative segregation within the prison pending an investigation into his role in the riot. The next day, respondent received notice of a misconduct charge against him. Five days after his transfer to administrative segregation, a Hearing Committee reviewed the evidence against respondent, and he acknowledged in writing that he had an opportunity to have his version of the events reported, but no finding of guilt was made. Subsequently, criminal charges based on the riot were filed against respondent, but were later dropped. In the meantime, a Review Committee concluded that respondent should remain in administrative segregation as posing a threat to the safety of other inmates and prison officials and to the security of the prison. Ultimately, the Hearing Committee, based on a second misconduct report and after hearing testimony from a prison guard and respondent, found respondent guilty of the second misconduct charge and ordered him confined to disciplinary segregation for six months, while dropping the earlier misconduct charge. Respondent sued in Federal District Court, claiming that petitioner prison officials' actions in confining him to administrative segregation violated his rights under the Due Process Clause of the Fourteenth Amendment. The District Court granted petitioners' motion for summary judgment. The Court of Appeals reversed, holding that, on the facts, respondent had a protected liberty interest in continuing to reside in the general prison population, which interest was created by the Pennsylvania regulations governing the administration of state prisons; that respondent could not be deprived of this interest without a hearing in compliance with the requirements of Wolff v. McDonnell, 418 U. S. 539; and that, since the court was uncertain whether the Hearing Committee's initial proceeding satisfied such requirements, the case would be remanded to the District Court for a hearing regarding the character of that proceeding.
1. Prison officials have broad administrative and discretionary authority over the institutions they manage, and lawfully incarcerated persons
retain only a narrow range of protected liberty interests. Administrative segregation is the sort of confinement that inmates should reasonably anticipate receiving at some point in their incarceration, and does not involve an interest independently protected by the Due Process Clause. But in light of the Pennsylvania statutes and regulations setting forth the procedures for confining an inmate to administrative segregation, respondent did acquire a protected liberty interest in remaining in the general prison population. Pp. 459 U. S. 466-472.
2. The process afforded respondent satisfied the minimum requirements of the Due Process Clause. Pp. 459 U. S. 472-477.
(a) In view of the wide-ranging deference accorded prison administrators in adopting and executing policies and practices needed to preserve order and discipline and to maintain security, petitioners were obligated to engage only in an informal, nonadversary review of the information supporting respondent's administrative confinement. P. 459 U. S. 472.
(b) Under Mathews v. Eldrige, 424 U. S. 319, the private interests at stake in a governmental decision, the governmental interests involved, and the value of procedural requirements are considered in determining what process is due under the Fourteenth Amendment. Here, respondent's private interest was not of great consequence, but the governmental interests in the safety of the prison guards and other inmates and in isolating respondent pending investigation of the charges against him were of great importance. Neither of the grounds for confining respondent to administrative segregation involved decisions or judgments that would have been materially assisted by a detailed adversary proceeding. Pp. 459 U. S. 473-474.
(c) An informal, nonadversary evidentiary review is sufficient both for the decision that an inmate represents a security threat and the decision to confine him to administrative segregation pending completion of an investigation into misconduct charges against him. In either situation, an inmate must merely receive notice of the charges against him and an opportunity to present his views to the prison official charged with deciding whether to transfer him to administrative segregation. Measured against these standards, respondent received all the process that was due after being confined to administrative segregation. Pp. 459 U. S. 476-477.
655 F.2d 487, reversed.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, POWELL, and O'CONNOR, JJ., joined. BLACKMUN, J., filed an opinion concurring in part and dissenting in part, post, p. 459 U. S. 478. STEVENS, J., filed a dissenting opinion, in which BRENNAN and MARSHALL,
JJ., joined, and in Parts II and III of which BLACKMUN, J., joined, post, p. 459 U. S. 479.