The Court's ruling in "Austin" was correct; however, it declined to impose additional procedural requirements, holding that notice and the opportunity to be heard are sufficient to meet the requirements of procedural due process. The Court should have developed a single liberty-interest standard that addresses the needs of inmates who face transfer to supermax prisons like OSP. Such a standard is necessary in order to provide adequate guidance to prison administrators and lower courts. Absent such a standard, future courts faced with similar challenges must struggle with a number of issues left unaddressed by the Court. One of these issues is whether a liberty interest can be invoked by either conditions of confinement that impose atypical and significant hardship or loss of parole eligibility. A second issue pertains to the baseline used to determine atypical and significant hardship. A third issue involves reconciling a previously defined list of procedural requirements with the balancing test specified in Mathews v. Elderidge (1976), in order to determine which of these requirements would benefit an inmate without overly burdening the government. 227 footnotes