The Supreme Court began to extend procedural due process rights to prisoners in 1972. In Morrissey v. Brewer, the Court explicitly articulated its recognition that prisoners retain the fundamental right to liberty guaranteed by the Constitution. Subequently, in Wolff v. McDonnell, the Court said that due process is implicated whenever misbehavior is punished by a substantial change in the prisoner's condition of confinement. Two years after Wolff, the Supreme Court established a new approach for adjudicating prisoners' due process claims. This approach was grounded in the fear that the demise of the separation of powers concept was imminent, especially if the Court continued to come between prison administrators and their prisoners. Two cases, Meachum v. Fano and Montanye v. Hayme, are discussed to illustrate that the Supreme Court has retreated to its 'hands-off' approach to inmate litigation. The Olim v. Wakenikona case is highlighted. The case involved a due process challenge by a prisoner that his involuntary interstate transfer from a Hawaiian prison to a California prison violated his right to liberty protected by the Constitution and insured through the due process clause of the 14th amendment. The Supreme Court held that the transfer was constitutionally acceptable. Implications of the decision are analyzed. Included are 128 references.