## Facts

- Gerald Hill and Joseph Crawford were inmates at a Massachusetts state prison.
- After an altercation in a prison walkway, they were charged with assaulting another inmate in violation of prison rules.
- A correctional officer reported hearing commotion, finding an inmate who appeared to have just been assaulted, and seeing three inmates—including Hill and Crawford—fleeing down the walkway.
- At separate disciplinary hearings, the board considered the officer’s written report and testimony.
- Hill and Crawford denied involvement; the injured inmate made statements indicating they did not cause his injuries.
- The disciplinary board found both guilty, revoked a total of 100 days of good-time credit, and imposed 15 days of solitary confinement.
- The superintendent denied administrative relief.
- State courts ordered restoration of good-time credits, concluding the disciplinary findings lacked constitutionally adequate evidentiary support.
- The U.S. Supreme Court granted review.

## Issues

1. Whether the Fourteenth Amendment Due Process Clause requires judicial review of prison disciplinary decisions affecting good-time credits.
2. Assuming good-time credits are a protected liberty interest, what evidentiary support due process requires to revoke them—specifically, whether “some evidence” is sufficient.

## Decision

- The Court reversed and remanded.
- It declined to decide whether due process independently requires judicial review because state law, as construed by the state’s highest court, already provided such review.
- Assuming good-time credits implicate a liberty interest, the Court held due process requires only that revocation be supported by “some evidence” in the record.
- The officer’s report and testimony that respondents were seen fleeing from the area of a recent assault constituted “some evidence,” and the record was not so devoid of support as to make the findings arbitrary.

## Legal Principles

- When prison discipline results in loss of good-time credits (assuming a protected liberty interest), due process is satisfied if the decision is supported by “some evidence.”
- Review under the “some evidence” standard is highly deferential: courts do not reweigh evidence, reassess witness credibility, or examine the entire record to determine whether the decision was correct.
- The constitutional question is limited to whether any evidence in the record could support the disciplinary board’s conclusion, preventing arbitrary deprivations while preserving institutional administrative interests.

## Conclusion

The Court set a minimal evidentiary floor for prison discipline that revokes good-time credits, holding that due process is met when the board’s decision has “some evidence” support and is not arbitrary.


Superintendent, Mass. Corr. Inst., Walpole v. Hill, 472 U.S. 445 (1985)