U.S. Appeals Court: PAROLE-REVOCATION.

• Position: Brief Article

Hawkins v. Freeman, 195 F.3d 732 (4th Cir. 1999). A parolee was denied habeas relief by the district court and appealed. The appeals court reversed and remanded but on rehearing en banc the appeals court affirmed. The appeals court held that the act of a state parole commission in revoking an erroneously granted parole did not shock the conscience and thus did not constitute a substantive due process violation when viewed as an executive act. Although the...