AT LEAST THREE STATES AND THE FEDERAL GOVERNMENT HAVE ADOPTED ENHANCED SENTENCING STATUTES, PROVIDING FOR A PERIOD OF CONFINEMENT BEYOND THE STATUTORY MAXIMUM FOR THOSE PROVEN TO BE ASSOCIATED WITH ORGANIZED CRIMINAL ACTIVITY. IN CATALANO V. U.S. (1974), A FEDERAL DISTRICT COURT HELD THAT 'SPECIAL OFFENDER' CLASSIFICATIONS WHICH ACT AS A BAR TO FURLOUGH, TRANSFER TO COMMUNITY PROGRAMS, OR TO DELAY OR DENY PAROLE CANNOT BE LEVIED WITHOUT NOTICE, A HEARING, OR OTHER ELEMENTS OF DUE PROCESS. IN CARDAROPOLI V. NORTON (1975), THE SECOND CIRCUIT COURT OF APPEALS INCREASED THE DUE PROCESS REQUIREMENTS, OUTLINING SPECIFIC PROCEDURAL SAFEGUARDS. WITH INCREASING REGULARITY, COURTS ARE CONCLUDING THAT THE BEST PROTECTION AGAINST ABUSE OF PROCESS LIES IN THE REQUIREMENT THAT A DUE PROCESS HEARING BE AFFORDED THE INMATE....MSP