Superintendent, Mass. Correctional Institution at Walpole v. Hill

The Court treated the question as unnecessary to resolve. Although it had never held that due process independently creates a right to judicial review of prison disciplinary proceedings, it also refused to read Ortwein v. Schwab as holding that judicial review can never be constitutionally required when an administrative decision affects a protected interest.

Massachusetts General Laws chapter 249, section 4 authorized a civil action in the nature of certiorari to correct legal errors in otherwise unreviewable administrative proceedings. Massachusetts decisions established that this procedure could be used to challenge whether evidence was legally sufficient to support an administrative adjudication, including prison disciplinary rulings.

Because state law supplied review for respondents' claims, the Court followed its usual rule of constitutional avoidance. It therefore left open whether the Federal Constitution would require judicial review if state law foreclosed it.

Under Wolff v. McDonnell, an inmate is entitled to specified procedural protections before losing good-time credits. Massachusetts did not dispute that its statutory credits created a protected liberty interest. Because revocation lengthens the inmate's actual confinement, the inmate has a substantial interest in protection against an arbitrary deprivation.

Due process is flexible and must account for the prison setting. Prison discipline occurs in a closed and potentially dangerous environment, where officials must preserve security, avoid procedures that can be manipulated, and retain an effective means of institutional discipline and rehabilitation.

A requirement that there be some evidence for the decision provides a basic safeguard against arbitrary action without imposing substantial new burdens. Wolff already requires a written statement identifying the evidence relied upon and the reasons for discipline, so the evidentiary requirement fits naturally with the existing procedural framework.

The Court rejected a more demanding constitutional standard, such as substantial evidence or criminal-trial proof. Reviewing courts need not examine the whole record, assess witness credibility, weigh competing proof, or decide whether they would have reached the same result. The only question is whether any evidence in the record could support the disciplinary board's conclusion.

Maguire heard a commotion, immediately found Stephens visibly injured, observed dirt consistent with a struggle, and saw Hill, Crawford, and a third inmate jogging away together from an enclosed walkway where no other inmates were present. This circumstantial evidence supported the board's conclusion that the three inmates had acted together in the assault.

The evidence was meager and did not directly identify which inmate struck Stephens. But the some-evidence standard does not require proof that logically excludes every conclusion other than the board's finding. It requires only a factual basis sufficient to keep the disciplinary ruling from being wholly unsupported or arbitrary.

Respondents relied solely on the Federal Due Process Clause and did not argue that the evidence failed to meet a stricter standard imposed by Massachusetts law. Because the record contained some evidence of their involvement, the Court reversed the state court's constitutional ruling and remanded for further proceedings.