The U.S. Supreme Court case Wolff v. McDonnell in 1973 revolved around the rights of prisoners during disciplinary proceedings. Robert O. McDonnell, an inmate at Nebraska Penal and Correctional Complex, filed a lawsuit against prison officials for violating his constitutional rights by imposing disciplinary sanctions without due process of law. The court ruled that while inmates do not have the full extent of due process protections as unincarcerated citizens when it comes to institutional discipline, they are still entitled to certain minimal protections under the Fourteenth Amendment's Due Process Clause. These include being notified of charges at least 24 hours before their hearing; having an opportunity to call witnesses and present documentary evidence (unless doing so would jeopardize institutional safety or correctional goals); receiving a written statement from fact finders about evidence relied on and reasons for disciplinary action taken; however there is no right to counsel or cross-examination in such hearings. This ruling clarified that while prisons may curtail many freedoms for legitimate penological interests, they cannot completely disregard basic procedural safeguards when determining whether an inmate has committed serious misconduct warranting punishment.

In the case of Wolff v. McDonnell, Justice Douglas dissented from the majority opinion. He argued that due process rights should extend to prisoners in disciplinary hearings and that these proceedings should be as formal as those outside prison walls. He believed that inmates have a constitutional right to confront and cross-examine witnesses against them during such hearings, which was not upheld by the majority ruling. Furthermore, he contended that any evidence used in these proceedings must meet legal standards for reliability and credibility - again something not required under the court's decision. In essence, Douglas felt strongly about maintaining procedural safeguards within prisons to protect inmate rights; he saw this as essential for upholding justice even within penal institutions.