In the case of Ponte, Superintendent, Massachusetts Correctional Institution v. Real in 1984, the U.S. Supreme Court ruled that prison officials are not required to explain their reasons for transferring a prisoner from one facility to another unless they have promised to do so. The court held that due process does not require an explanation for every decision made by prison administrators and there is no constitutional right for prisoners to remain at a particular institution or be housed in a specific part of an institution. This ruling was based on the principle that prisons need flexibility and discretion in managing their populations and maintaining security within their facilities.

In the dissenting opinion for Ponte v. Real, Justice Brennan argued that due process requires prison officials to provide written reasons when they decide to hold a disciplinary hearing in solitary confinement rather than in an open forum. He believed this requirement was necessary because it would allow courts to ensure that such decisions are not arbitrary or capricious and do not infringe upon prisoners' rights unnecessarily. Furthermore, he contended that providing written reasons would not impose an undue burden on prison administrators as majority suggested but instead promote better decision making by forcing them to articulate their reasoning. Justice Brennan also disagreed with the majority's view of Wolff v. McDonnell, arguing that it did establish a right for inmates facing disciplinary charges to call witnesses and present documentary evidence in their defense unless doing so would be unduly hazardous.