In the case of Superintendent, Massachusetts Correctional Institution at Walpole v. Hill et al., 1984, the U.S. Supreme Court ruled that a prison disciplinary board's decision must be upheld if there is "some evidence" to support it. The case involved two inmates who were found guilty by a prison disciplinary board for their involvement in an assault on another inmate and subsequently lost good-time credits as part of their punishment. They filed suit claiming that they had been denied due process because the findings of the disciplinary board were not supported by sufficient evidence. However, the Supreme Court held that while prisoners are entitled to certain procedural protections under the Due Process Clause, these do not include a right to judicial review of factual determinations made by prison officials in disciplinary proceedings so long as there is some evidentiary basis for their decisions.

In the dissenting opinion for Superintendent, Massachusetts Correctional Institution at Walpole v. Hill et al., Justice O'Connor disagreed with the majority's interpretation of the "some evidence" standard in prison disciplinary hearings. She argued that this standard should not be so minimal as to include any evidence whatsoever, no matter how meager or unreliable it may be. Instead, she suggested a more robust requirement where there must be some reliable and credible evidence presented to support a decision in such hearings. This would ensure fairness while still recognizing the unique challenges and constraints present within correctional institutions. Furthermore, Justice O'Connor expressed concern that by setting such a low bar for evidentiary standards could potentially lead to arbitrary decisions based on unsubstantiated accusations or rumors which would undermine prisoners' rights and due process protections.