Sandin v. Conner

Prison inmate Conner (defendant, on habeas as respondent) was disciplined for reacting angrily during a strip search and, after a hearing where he wasn't allowed to call witnesses, was sentenced to 30 days of disciplinary segregation. Months after Conner served the sentence and filed suit alleging a due-process violation, prison officials found the misconduct charge unjustified and expunged it. The district court granted summary judgment to the prison, but the court of appeals reversed, reasoning that prison regulations requiring misconduct findings to be backed by substantial evidence created a state-created liberty interest.