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
- Whether the Fourteenth Amendment Due Process Clause requires judicial review of prison disciplinary decisions affecting good-time credits.
- 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.