Cite as: 515 U. S. 472 (1995)
Opinion of the Court
125 (1977). Such flexibility is especially warranted in the fine-tuning of the ordinary incidents of prison life, a common subject of prisoner claims since Hewitt. See, e. g., Klos v. Haskell, 48 F. 3d 81, 82 (CA2 1995) (claiming liberty interest in right to participate in "shock program"—a type of boot camp for inmates); Segal v. Biller, No. 94-35448, 1994 U. S. App. LEXIS 30628 (CA9, Oct. 31, 1994) (unpublished) (claiming liberty interest in a waiver of the travel limit imposed on prison furloughs); Burgin v. Nix, 899 F. 2d 733, 735 (CA8 1990) (claiming liberty interest in receiving a tray lunch rather than a sack lunch); Spruytte v. Walters, 753 F. 2d 498, 506-508 (CA6 1985) (finding liberty interest in receiving a paperback dictionary due to a rule that states a prisoner " 'may receive any book . . . which does not present a threat to the order or security of the institution' ") (citation omitted); Lyon v. Farrier, 727 F. 2d 766, 768-769 (CA8 1984) (claiming liberty interest in freedom from transfer to a smaller cell without electrical outlets for televisions and liberty interest in a prison job); United States v. Michigan, 680 F. Supp. 270, 277 (WD Mich. 1988) (finding liberty interest in not being placed on food loaf diet).
In light of the above discussion, we believe that the search for a negative implication from mandatory language in prisoner regulations has strayed from the real concerns under-girding the liberty protected by the Due Process Clause. The time has come to return to the due process principles we believe were correctly established and applied in Wolff and Meachum.5 Following Wolff, we recognize that States
5 Such abandonment of Hewitt's methodology does not technically require us to overrule any holding of this Court. The Court in Olim v. Wakinekona, 461 U. S. 238 (1983), and Kentucky Dept. of Corrections v. Thompson, 490 U. S. 454 (1989), concluded no liberty interest was at stake. Although it did locate a liberty interest in Hewitt, it concluded that due process required no additional procedural guarantees for the inmate. As such, its answer to the anterior question of whether the inmate possessed a liberty interest at all was unnecessary to the disposition of the case. Our decision today only abandons an approach that in practice is difficult to administer and which produces anomalous results.
483
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