Ponte v. Real

• Jurisdiction: United States

Ponte v. Real

471 U.S. 491 (1985)

Facts

Respondent John Real was an inmate at the Massachusetts Correctional Institution at Wolpole. In December 1981, Real was working in the prison metal shop when he heard a commotion in an adjacent office. He entered the office and observed an inmate fighting with a correctional officer. A second correctional officer attempted to break up the fight and ordered Real out of the office, but Real remained in the office observing the fight. Another correctional officer ended up escorting Real to his cell. A week later, Real received notice that he was charged with three violations of prison regulations as a result of his refusal to leave the room where the brawl took place. He notified prison authorities that he wanted to call four witnesses at a hearing that would be held on these charges: two prisoners, the charging officer, and the officer who was involved in the fight. A hearing was held in February 1982. At the hearing, the charging officer appeared and testified against Real, but the board declined to call any other witnesses and did not indicate on the record of the hearing why they refused to call the other witnesses. Real was found guilty and received 25 days in isolation and the loss of 150 days good time credit. He then sought a writ of habeas corpus in a Massachusetts trial court, which sustained his claim that prison officials had deprived him of his Fourteenth Amendment due process rights because they gave no reasons why he was not allowed to call the requested witnesses at the hearing. On appeal, the Massachusetts Supreme Judicial Court affirmed the holding that prison authorities violated Real's due process rights by not putting in the administrative record the reasons he was denied the opportunity to call witnesses in his defense and declared a Massachusetts statute that governed the presentation of proof in prison disciplinary hearings unconstitutional because it did not require prison officials to record the facts or reasons for denying a prisoner's witness request. The U.S. Supreme Court granted certiorari.

Issue

Whether the Due Process Clause of the Fourteenth Amendment requires prison officials to record reasons for denying a prisoner the opportunity to call witnesses on their behalf in the administrative record of prison disciplinary hearings.

U.S. Supreme Court Holding

The U.S. Supreme Court vacated and remanded the case back to the Massachusetts Supreme Judicial Court, holding that the Due Process...