Wolff v. Mcdonnell, 418 U.S. 539 (1974)

Wolff v. McDonnell, 418 U.S. 539 (1974)

Bell v. Wolfish, 441 U.S. 520 (1979)

Estelle v. Gamble, 429 U.S. 97 (1976)

Procunier v. Martinez, 416 U.S. 396 (1974)

Facts: In Wolff v. Mcdonnell, 418 U.S. 539 (1974), the inmates at a Nebraska prison filled a complaint against disciplinary measures at the prison contrary to the due process. In it they outlined the short comings of the prisons legal assistance program in meeting constitutional standards. They added that the prison's regulations governing inmates' mail were also unconstitutionally restrictive.

In the Bell v. Wolfish, 441 U.S. 520 (1979), the inmates filed a class action suit in the Court of Appeal against constitutionality of various confinement and practices in the Metropolitan Correctional Center. These included double bunking, publisher only rule, restricting books intended for inmates, prohibition of food and other items from outside as well as unnecessary inmate body cavity searches.

In Estelle v. Gamble, 429 U.S. 97 (1976), the respondent inmate filed a civil rights action against the Texas Department of Corrections medical director and two other officials who he claims subjected him to cruel and unusual punishment that violated his rights under the Eighth Amendment.

In the same line, the Procunier v. Martinez, 416 U.S. 396 (1974), was a class action opposing prisoner mail restriction regulations issued by the Director of the California Department of Corrections. In addition they also opposed the prohibition of the use of law students and legal paraprofessionals in conducting attorney-client interviews with prisoners.

Issue: Did the District Courts err in failing to rule in favor of the inmates thereby denying their rights because of their status?

Decisions: In Wolff v. McDonnell, 418 U.S. 539 (1974) the Court of Appeals reversed the first ruling by the District court holding that in prison disciplinary proceedings, the outlined procedural requirements in Morrissey v. Brewer, 408 U.S. 471, and Gagnon v. Scarpelli, 411 U.S. 778, must be followed. The Court of Appeal agreed with the Districts Court's decision on attorney correspondence. On the third ruling, the court added prescriptions and ordered further proceedings to examine whether the state was abiding by the law in provision of legal assistance to prisoners under Johnson v. Avery, 393 U.S. 483 (1969).

In Bell v. Wolfish, 441 U.S. 520 (1979), the Court of Appeals upheld by affirming the rulings by the District Court that "double-bunking" practice that the MCC failed to show "compelling necessity" enough to justify such practice. Such practices as mentioned in the case do not deprive pretrial detainees of their liberty without due process of law in contravention of the Fifth Amendment.

In Estelle v. Gamble, 429 U.S. 97 (1976), the Court of Appeals reversed the dismissal of the case by the District Court on the ground that it failed to state a claim upon which relief could be granted.

In Procunier v. Martinez, 416 U.S. 396 (1974) The Court also ruled against the use of law students and legal paraprofessionals in conducting attorney-client interviews with prisoners. The court also decided to censor the delivery of letters holding that this process must be follow minimum procedural safeguards against arbitrariness or error.

Reasoning: The Courts reasoned that in case a prison disciplinary hearing results to loss of good-time credits, due process demands that the prison gives the inmate a prior notification of a hearing so that the inmate can avail witnesses as well as provide documentary evidence. This is in line with all the cases. In Bell v. Wolfish, 441 U.S. 520 (1979), the issue of double-bunking did not amount to punishment as a matter of law, therefore did not violate respondents' rights under the Due Process Clause of the Fifth Amendment.

In regard to the inmate mail, the Courts reasoned that the state is constitutionally required to ascertain that mail from an attorney to a prisoner is identified as such. It is a requirement that the names of the inmate, address appear on the mail as protection and that the authorities are only allowed to open the letter in the presence of the inmate. Attorneys wishing to correspond with an inmate are subject to requirements such as identification to the authorities to ensure that letters labeled "privileged" are authentic and from members of the bar. In Procunier v. Martinez, 416 U.S. 396 (1974), the courts upheld personal mail censorship, which unlike the attorney correspondence was likely to contain "unduly complain[ed]," "magnif[ied] grievances," "express[ed] inflammatory political, racial, religious or other views or beliefs," or contained matter deemed "defamatory" or "otherwise inappropriate."

I regard to the ruling on the adequacy of the legal assistance in the In Wolff v. McDonnell, 418 U.S. 539 (1974), it was based on the reasoning that it is a civil rights matter that can be explored further in line with Avery, supra, at 490. However, in Procunier v. Martinez, 416 U.S. 396 (1974), the courts instituted a ban on attorney-client interviews conducted by law students or legal paraprofessionals. The court's reasoning here was that the latter was not a legal right.