Conner was sentenced to 30 years to life for murder, kidnapping, and burglary in Hawaii. While serving time in a maximum-security prison, he was subjected to a strip search and a rectal examination, during which he directed foul language at the correctional officer. Conner was formally charged with disciplinary infractions of high misconduct for physical obstruction of a correctional function and low moderate misconduct for abusive language toward a correctional officer. When he appeared before a prison disciplinary committee, his request to present witnesses was refused and he was found guilty and sentenced for the infractions. Conner later brought suit, alleging deprivation of his rights. The case went to the U.S. Supreme Court where the majority opinion held Hawaii prison regulations and the due process clause of the 14th amendment did not offer Conner a protected liberty interest that would entitle him to procedural due process rights in prison disciplinary proceedings. The interpretation of Sandin v. Conner by Federal appeal courts is discussed, and the authors note future prison inmates will have a more difficult time establishing a case for state-created liberty interests. 48 references, 4 notes, and 2 tables