In order to facilitate an understanding of the current state of prisoners' protected rights, this Note first discusses the historical development of those rights. It then examines the Connecticut Board of Pardons v. Dumschat opinion in light of the previous decisions of the United States Supreme Court regarding prisoners' due process rights. Finally, this Note discusses Dumschat's role in the Court's continued narrowing of the threshold criteria required for prisoners to establish liberty interests worthy of constitutional protection.

I. Introduction

II. Historical Rights of Prisoners

III. The Dumschat Decision … A. Lower Court Opinions … B. Supreme Court Decision

IV. Analysis … A. The Critical Difference … B. A Unilateral Hope … C. Encumber for No Good Reason

V. Conclusion