One of the most important cases providing a delineation of inmates' constitutional status and of the constitutional limits on penal administrators' discretion, is Wolff v. McDonnell. The case is significant because of its discussion of inmates' constitutional status and because it provides legal recognition of prison inmates' rights and privileges. Decisions in two prison cases, Kelly v. Brewer and Clark v. Brewer, illustrate the evolution of the role of the judicial branch in overseeing the operation of the Iowa State Penitentiary (ISP) and specifically, in regard to Administrative Solid Lockup (ASL). Prior to the Kelly decision, the ISP prison administrators had unbridled discretion in determining the placement of an inmate in ASL. The decision, based on due process grounds, required the prison administration to adopt a single plan establishing forth the factors to be considered periodically by prison officials in determining if a prisoner's ASL status should be continued. The district court declared that the overriding issue in the Clark decision was whether an inmate, once placed in close management (CM), possessed a liberty interest in not being retained indefinitely in CM that was protected by due process. The court determined that a distinction existed between being placed in CM and being retained in CM. The Constitution must be applicable to prisoners; otherwise, State governments and prison administrators can too easily revert to the 'slave of the state' doctrine of unfettered discretion without review.