June 13, 2005

United States Supreme Court

Background: Current and former inmates housed at state supermax prison brought class action against prison officials under § 1983, alleging that state's policy governing placement in the supermax prison did not afford procedural due process in violation of the Fourteenth Amendment. The United States District Court for the Northern District of Ohio, 189 F.Supp.2d 719, ruled that the policy denied due process, and ordered modifications, 204 F.Supp.2d 1024. Prison officials appealed. The Court of Appeals for the Sixth Circuit, 372 F.3d 346, affirmed in part, reversed in part and remanded. Prison officials applied for certiorari which was granted.

Holdings: The Supreme Court, Justice Kennedy, held that:
(1) inmates had a liberty interest protected by the Fourteenth Amendment's Due Process Clause in avoiding assignment to state's supermax prison, and
(2) state's informal, nonadversary procedures for placement of inmate in supermax prison were ade-quate to safeguard inmate's liberty interest in not being assigned to supermax facility.

Affirmed in part, reversed in part and remanded.