Two of the most important cases involving prisoners' rights in the last century are Sandin v. Conner and Whitley v. Alberts. In the case of Sandin v. Conner, DeMont Conner, an inmate at a maximum security correctional facility in Hawaii, was subjected to a strip search in 1987. During the search, he directed angry and foul language at the officer. Conner was charged with gross misconduct and sentenced to 30 days of solitary confinement by the adjustment committee. Conner was not allowed to present witnesses in his defense. Conner served his sentence in solitary confinement for 30 days, after which he requested a review of his case. Upon review, the prison administration found no evidence to support the allegation of professional misconduct. The state district court upheld the decision, but the Ninth Circuit Court of Appeals found that Sandin had an interest in remaining free from disciplinary segregation. This case is important because it raises the question of what constitutional rights individuals retain while incarcerated. In the case of Sandin v. Conner, the Supreme Court ultimately ruled that detainees are entitled to due process only when an “atypical and significant deprivation” has occurred. Prisons must now be vigilant in protecting the rights of prisoners. This is a delicate issue in the sense that when an individual enters prison, their right to liberty is largely lost. The rights in question are important for prisoners because prisons are closed environments where, by their nature, their freedoms are already very limited. They need a well-defined set of rights so that prisons do not unduly infringe on their freedom. Without court intervention, prison administrators would likely not have granted this particular right, as it adds another layer of bureaucracy that can be seen as interfering with the effectiveness of their work. Additionally, it could lead to a glut of prisoners claiming violations of their rights under the court ruling. The case Whitley v. Albers concerns the use of force by prison staff on inmates. Harold Whitley, a corrections officer at the Oregon State Penitentiary, fatally shot inmate Gerald Albers in the knee during a disturbance in 1983. This called into question several factors, including the need for force, the relationship between the need and amount of force. the force used, the extent of the injuries inflicted, the threat to the safety of other detainees and the efforts made to avoid a violent response. The Supreme Court ruled in favor of the prison, concluding that guards responding to disturbances at the prison must act maliciously and sadistically with the intent to cause harm to qualify as cruel and unusual punishment..