The Note traces the development of the Due Process Clause and its relation to convicted prisoners, and examines the Supreme Court decision in Sandin v. Conner. The decision in that case gives prison administrators and the State considerable discretion, in the interest of security, to dictate the regulations of their prisons. Given the trend of the US Supreme Court to limit the number of cases heard, the question whether "atypical and significant hardship" results in any given situation will fall primarily on the lower courts to resolve. The Note also examines three major issues raised by the transfer of 299 Massachusetts prisoners on November 2, 1995: (1) whether the prisoners had a protected right to remain within the prison system of a certain State under preexisting law; (2) whether the prisoners had a protected right to remain within the prison system of a certain State under Sandin v. Connor; and (3) whether the Constitution requires any procedural safeguards for future interstate prisoner transfers. Notes