In the case of Cleavinger et al. v. Saxner et al., 1985, the U.S Supreme Court ruled that members of a prison disciplinary committee were not entitled to absolute immunity from lawsuits filed by inmates for alleged constitutional violations during disciplinary proceedings. The court held that these officials should only be granted qualified immunity, which protects them from liability as long as their actions do not violate clearly established statutory or constitutional rights that a reasonable person would know about. This decision was based on an examination of six factors used to determine whether certain government officials are entitled to absolute immunity: (1) performance of adjudicative functions; (2) existence in history; (3) insulation from political influence; (4) importance of precedent; (5) adversarial nature and correctability through appeal processes, and finally, if they were comparable to judges or prosecutors who traditionally receive such protection under common law.

In the dissenting opinion for Cleavinger et al. v. Saxner et al., Justice White disagreed with the majority's decision to extend absolute immunity to members of a prison disciplinary committee, arguing that it was an overreach and not in line with previous court decisions on similar matters. He contended that such committees should only be granted qualified immunity, which would protect them from liability as long as they did not violate clearly established statutory or constitutional rights of which a reasonable person would have known. Justice White believed this level of protection was sufficient and more appropriate given their roles and responsibilities within the prison system. He also expressed concern about potential abuses if these individuals were shielded by absolute immunity, suggesting it could lead to violations of prisoners' rights without any legal recourse.