On April 21, 1976, the United States Supreme Court heard oral arguments in the case of Meachum v. Fano. State prisoners, who were believed to be disruptive, sued to prevent their transfer to a less desirable facility. The issue on appeal was—is it a violation of the 14th Amendment (the Due Process Clause) for a State to unilaterally transfer an inmate to another prison without conducting a fact-finding hearing? On June 25, 1976, the United States Supreme Court held, in a 6-3 decision, that it wasn’t unconstitutional. The Court found inmates enjoy no entitlement to reside at a particular prison.
Justice White explained–”The Constitution does not…guarantee that the convicted prisoner will be placed in any particular prison if, as is likely, the State has more than one correctional institution. The initial decision to assign the convict to a particular institution is not subject to audit under the Due Process Clause, although the degree of confinement in one prison may be quite different from that in another. The conviction has sufficiently extinguished the defendant’s liberty interest to empower the State to confine him in any of its prisons.”