Although the courts have prompted procedural, due process reforms in inmate disciplinary proceedings, the rate and level of punishment has not changed. The courts did not intend that their procedural reforms should transform the power structure of the prison. The outcome of the procedures is still to give decisionmaking power to the prison administration. The state is simply required to rationalize its legitimate interests of deterrence, security, control, and even rehabilitation through its disciplining of inmates. The courts have consistently afforded prison administrators great discretion in substantive if not procedural decisions. Inmate litigation has been advanced as a mechanism of inmate democratic power, but the outcome of the use of this mechanism has been the legitimation of state control over inmates under the guise of protecting inmates' rights. The courts, which sentence offenders to prison under the rhetoric of justice, are not likely to accord these offenders rights which undermine punitive sentencing goals. 2 notes and 31 references.