Case Analysis Essay on Wolff v. McDonnell: Inmate's Unsuccessful Suit for Due Process Rights

Introduction

Wolff v.McDonnell, 418 U.S. 539 (1974) was a case in United States Supreme Court, in which a Nebraska Penal and Correction Complex inmate -Robert McDonnell, failed a lawsuit against Charles Wolff Jr who was a warden institution. McDonnell claimed that the hearing of the disciplinary cases in prison were against due process as described in the Fourteenth Amendment and, besides, the legal representation in prison did not meet the standards stipulated by the U.S constitution.

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In the case, due process is the understanding of various issues set by the Nebraska status and prison policies that require that the prison disciplinary cases be detailed. According to the prison policies provided in section 16 of the institution's Act, the chief executive have the responsibility of disciplining inmates within their penal facility. Besides, the Act recommended several disciplinary actions. The statues state that disciplinary for misconduct shall be denying the offender privileges. In the case of severe or flagrant misconduct, however, the ECO may order that the term of the offender be reduced under section 83-1, 107. In this case, the reduction of times imply to the withholding or forfeiting the offender's good-time credit and that the individual is confined to the disciplinary cell. The statue further stated that each disciplinary case, together with the punishment or disposition, be recorded in the affected inmate's file (Wright, 2016).

According to McDonnel, the disciplinary proceeding in the complex involving the inmate receiving oral information about the charges labeled to him, the committee writing a report that will be read to the inmate during the hearing. If the prisoner denied the charge against him, the committee would conduct inquiries on their own; however, they would not present any witness or conduct a cross-examination. The hearing will then impose penalties that include the loss of good-time credits. McDonnel, therefore, argued that the failure of the prison authorities to allow the prisoner to conduct a cross-examination or present witnesses meant that the hearings did not meet the constitutional standard. Secondly, the fact that the committee, instead of the chief executive officer ordering the reduction or loss of good-time credits, did not follow the due process provided in the Fourteenth Amendment (Harrington, 2015). The 14th Amendment prohibits the state from denying any individual property, liberty, or liberty without the due process of the law. According to the Amendment, every accused person should enjoy the equal protection of the law. Besides, McDonnel claimed that the prison's mail regulations that allow the inspection of both the outgoing and incoming mails were against the 14th Amendment.

On hearing the case, the Supreme Court ruled that indeed, the authority of the prison violated the Fourteenth Amendment due process clause. In a vote of 6-3, the Supreme Court ruled that, even though the law does not give the inmate full protection of the due process, the disciplinary proceedings must comply with a particular aspect of due processes. The disciplinary process should include the defendant receiving written notice about the charges as well as the presence of a written statement of evidence. That accused inmate can present evidence and call witnesses (Steiner, & Cain, 2017). However, the court allowed the prison official to deny the prisoners the right to request witness or prevent evidence by their discretion if they feel that by doing so, it may be dangerous to the safety of the institution. The court also ruled that the process where the prison officials open the incoming privilege letters while other inmates are present was constitutional (Morgen, 1974). The other judges argued that prisoners are entitled to full protection of the due process in the fourteenth Amendment and should not be bridged.

Conclusion

Form the discussion above; it is evident that Nebraska Penal and Correction Complex violated the law the due process clause as provided in the 14th Amendment. Even though prisoners are not entitled to full protection by the 14th Amendment, they are entitled to the protection of law if the case involves them losing their liberty, life, or property.

References

Harrington, M. P. (2015). Methodological challenges to the study and understanding of solitaryconfinement. Fed. Probation, 79, 45. Retrieved from https://heinonline.org/HOL/LandingPage?handle=hein.journals/fedpro79&div=33&id=&page=

Morgen, B. A. (1974). Wolff v. McDonnell: The Handwriting on the Prison Wall. New Eng. L. Rev., 10, 509. Retrieved from https://heinonline.org/HOL/LandingPage?handle=hein.journals/newlr10&div=28&id=&page=

Steiner, B., & Cain, C. M. (2017). Punishment within the prison: An examination of the influences of prison officials' decisions to remove sentencing credits. Law & Society Review, 51(1), 70-98. Retrieved from https://onlinelibrary.wiley.com/doi/abs/10.1111/lasr.12250

Wright, B. N. (2016). The Prison Law Library: A Fourteenth Amendment Necessity. In Perspectives on Libraries as Institutions of Human Rights and Social Justice (pp. 209-228). Emerald Group Publishing Limited. Retrieved from https://www.emerald.com/insight/content/doi/10.1108/S0065-283020160000041008/full/html