Two of the most significant prisoner rights cases of the last century are Sandin v. Conner and Whitley v. Albers. In the case of Sandin v. Conner, DeMont Conner, an inmate at a maximum security penitentiary in Hawaii, was subjected to a strip search in 1987. During the strip search he directed angry and vulgar language at the officer. Conner was charged with gross misconduct and sentenced to 30 days of segregation by the Board of Adjustment. Conner was not allowed to present witnesses in his defense. Conner completed his 30-day segregation sentence, after which he requested a review of his case. After examination, the prison administration found no evidence to support the accusation of misconduct. The state district court upheld the decision, but the Ninth Circuit Court of Appeals found that Sandin had a liberty interest in remaining free from disciplinary segregation. This case is significant because it addresses the question of what constitutional rights individuals retain when incarcerated. In Sandin v. Conner, the Supreme Court ultimately ruled that prisoners are entitled to due process only when “atypical and significant deprivation” has occurred. Prisons must now be vigilant in protecting the rights of prisoners. It is a sensitive issue in the sense that when an individual enters prison, their rights to liberty are largely lost. The rights in question are important for prisoners because prisons are closed environments where by nature their freedoms are already very limited. They need a well-defined set of rights so that prisons do not unduly infringe on their freedom. Without court intervention, prison administrators would likely not have granted this particular right, as it adds an additional layer of bureaucracy that can be seen as interfering with the efficiency of their work. Furthermore, this could lead to an excess of prisoners complaining of violations of their rights based on the court's ruling. The case of Whitley v. Albers concerns the use of force by prison staff on inmates. Harold Whitley, a correctional officer at the Oregon State Penitentiary, shot and wounded inmate Gerald Albers in the knee during a riot in 1983. This called into question several factors, including whether there was a need for force, the relationship between the need and the amount of force used, the extent of harm inflicted, the threat to the safety of other inmates, and the effort to avoid a violent response. The Supreme Court ruled in favor of the prison, concluding that guards responding to a prison disturbance must act maliciously and sadistically with the intent to cause harm to qualify as cruel and unusual punishment.