480
Opinion of the Court
The Court made explicit in Hewitt what was implicit in Greenholtz. In evaluating the claims of inmates who had been confined to administrative segregation, it first rejected the inmates' claim of a right to remain in the general population as protected by the Due Process Clause on the authority of Meachum, Montanye, and Vitek. The Due Process Clause standing alone confers no liberty interest in freedom from state action taken " 'within the sentence imposed.' " 459 U. S., at 468. It then concluded that the transfer to less amenable quarters for nonpunitive reasons was "ordinarily contemplated by a prison sentence." Ibid. Examination of the possibility that the State had created a liberty interest by virtue of its prison regulations followed. Instead of looking to whether the State created an interest of "real substance" comparable to the good time credit scheme of Wolff, the Court asked whether the State had gone beyond issuing mere procedural guidelines and had used "language of an unmistakably mandatory character" such that the incursion on liberty would not occur "absent specified substantive predicates." Id., at 471-472. Finding such mandatory directives in the regulations before it, the Court decided that the State had created a protected liberty interest. It nevertheless, held, as it had in Greenholtz, that the full panoply of procedures conferred in Wolff were unnecessary to safeguard the inmates' interest and, if imposed, would undermine the prison's management objectives.
As this methodology took hold, no longer did inmates need to rely on a showing that they had suffered a " 'grievous loss' " of liberty retained even after sentenced to terms of imprisonment. Morrissey v. Brewer, 408 U. S. 471, 481 (1972) (citation omitted). For the Court had ceased to examine the "nature" of the interest with respect to interests allegedly created by the State. See ibid.; Board of Regents of State Colleges v. Roth, 408 U. S. 564, 571 (1972). In a series of cases since Hewitt, the Court has wrestled with the language of intricate, often rather routine prison guidelines
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