McKee v. Coughlin, 76 N.Y.2d 851 (1990)
Correction Law § 138(3) is satisfied when regulations give inmates notice of the tier level for each offense and the types of punishment that may be imposed for each tier, without specifying maximum time limits for sanctions.
Summary
McKee, an inmate, challenged a disciplinary determination, arguing that the regulations failed to provide adequate notice, as required by Correction Law § 138(3), regarding the maximum amount of time a Tier III penalty could be imposed. The Court of Appeals affirmed the Appellate Division’s judgment, holding that the regulations satisfied the statutory requirement by notifying inmates of the offense tiers and the types of penalties for each tier, even without specifying maximum time limits. This interpretation aligns with the statute’s purpose of ensuring inmates receive notice of prohibited conduct and its potential consequences.
Facts
While incarcerated at Wyoming Correctional Facility, McKee was charged with violating inmate behavior standards by inflicting bodily harm, creating a disturbance, and destroying state property. Following a Tier III disciplinary hearing, he was found guilty and received a penalty that included 180 days in special housing, loss of good time, and a modified diet. McKee argued the regulations were deficient for not stating the maximum time for Tier III penalties.
Procedural History
After exhausting his administrative appeals, McKee initiated an Article 78 proceeding challenging the Superintendent’s determination. The lower courts likely upheld the disciplinary determination, leading to an appeal to the New York Court of Appeals.
Issue(s)
Whether Correction Law § 138(3) requires regulations to specify the maximum amount of time for which a Tier III penalty may be imposed to provide adequate notice to inmates.
Holding
No, because the statutory requirement that the “range of disciplinary sanctions” be stated is satisfied by regulations that provide notice of the offense tier and types of punishment for each tier, without specifying maximum time limits.
Court’s Reasoning
The Court reasoned that Correction Law § 138(3) mandates “facility rules shall state the range of disciplinary sanctions which can be imposed for violation of each rule.” The Court found that the regulations informed inmates of proscribed conduct, offense level (Tier I, II, or III), and types of penalties. While regulations for Tier III offenses specified sanction types without time limits, the Court held that “the statutory requirement, that the ‘range of disciplinary sanctions’ be stated, is satisfied by the regulations which give notice of what tier each offense may be prosecuted under and what kinds of punishment may be imposed for each tier.” This aligns with the statute’s purpose of notifying inmates about prohibited conduct and its consequences. The Court emphasized that a stricter interpretation requiring specific time limits was unnecessary to achieve the statute’s intended purpose. The court found no merit in the petitioner’s remaining contentions.