Wolff v. McDonnell

Under a Nebraska prison’s policies, a prisoner’s supervisor handled any accusation of a single incident of minor misconduct. For repeated minor misconduct or serious violations, the chief corrections officer held a conference with the accused prisoner and the charging party, then submitted a report to a committee. Hours or days later, the prisoner met with the committee, often learning the full nature of the charges for the first time. The prisoner could question the charging party, and the committee could conduct an independent investigation. The committee could then impose penalties such as issuing a reprimand, restricting privileges, placing the prisoner in solitary confinement, or reducing good-time credits. Good-time credits were units a prisoner could earn for various reasons, including good behavior. Under state law, good-time credits could help a prisoner become eligible for parole sooner. Robert McDonnell (plaintiff) was incarcerated in the prison. McDonnell filed a class-action lawsuit against the prison’s warden, Charles Wolff (defendant), in federal district court. Among other claims, the lawsuit alleged that the prison’s disciplinary procedures violated due process by imposing penalties without sufficient procedural safeguards. The district court rejected the due-process claim, but the United States Court of Appeals for the Eighth Circuit reversed. The United States Supreme Court granted certiorari.