Sandin v. Conner and Whitley v. Albers

Two of the most significant inmates rights cases in the past century are Sandin v. Conner and Whitley v. Albers.

In the case of Sandin v. Conner, DeMont Conner, an inmate at a maximum security correctional facility in Hawaii, was subjected to a strip search in 1987. During the search he directed angry and foul language at the officer. Conner was charged with high misconduct and sentenced to 30 days of segregation by the adjustment committee. Conner was not allowed to present witnesses in his defense. Conner completed the 30-day segregation sentence, after which he requested a review of his case. Upon review, prison administration found no evidence to support the misconduct claim. The State District Court backed the decision, but the Ninth Circuit Court of Appeals found that Sandin had a liberty interest in remaining free from disciplinary segregation. This case is significant because it confronts the question of which constitutional rights individuals retain when they are incarcerated. In Sandin v. Conner, the Supreme Court ultimately ruled that prisoners have a right to due process only when “atypical and significant deprivation” has occurred. Prisons must now be vigilant in protecting the rights of inmates. It is a delicate matter in the sense that, when an individual enters prison, their rights to liberty are by and large being forfeited. The rights in question are important to prisoners because prisons are closed environments where by nature their freedoms are already very limited. They need a well-defined set of rights so that prisons do not unduly infringe on their liberty. Without court intervention, prison administrators would likely not have allowed this particular right, as it adds another layer of bureaucracy that can be seen as interfering with the efficiency of their job. Also, it could lead to a glut of prisoners claiming violations of their rights under the court ruling.

The case of Whitley v. Albers concerns the use of force by prison staffers on inmates. Harold Whitley, a corrections officer at the Oregon State Penitentiary, shot and wounded inmate Gerald Albers in the knee during a disturbance in 1983. This brought into question several factors, including whether there was a need for force, the relationship between the need and amount of force used, the extent of injury inflicted, threat of safety to other inmates, and effort to avoid a violent response. The Supreme Court ruled in favor of the prison, concluding that guards reacting to a prison disturbance must act maliciously and sadistically with intent to cause harm to qualify as cruel and unusual punishment.