Superintendent, Massachusetts Correctional Institution at Walpole v. Hill

Gerald Hill and Joseph Crawford (plaintiffs) were incarcerated in a Massachusetts prison. A prison guard filed a disciplinary report accusing them of assaulting another prisoner. Hill and Crawford had separate disciplinary hearings before a board. The only evidence presented against the prisoners was the guard’s testimony. The guard reported hearing a prisoner shout “What’s going on?” twice. The guard opened a door and saw a prisoner on the ground with a swollen eye and bleeding from the mouth. The area had dirt consistent with a scuffle. The guard saw Hill, Crawford, and another prisoner jogging away. No one else was around. The injured prisoner testified that no one had assaulted him, and Hill and Crawford denied involvement in any assault. The board determined that Hill and Crawford had committed an assault. As a penalty, both men were placed in solitary confinement for 15 days, and each lost 100 days of good-time credit. Good-time credits could help a prisoner become eligible for parole sooner. Hill and Crawford appealed the penalties through the prison system, but the appeals were denied. Hill and Crawford then sued the prison’s superintendent (defendant) in state court, alleging that the prison had violated their constitutional rights by arbitrarily depriving them of their liberty interests in the good-time credits without due process. Hill and Crawford argued the penalties were unconstitutionally arbitrary because there was no direct evidence that any assault occurred or, if it had, that they were involved. The state trial court agreed, finding a due-process violation, and the state’s highest court affirmed. The United States Supreme Court granted certiorari.