Until the 1970s, disciplinary procedures conducted in prisons could be exercised without challenge because the prisoner was legally in the hands of the state.

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Until the 1970s, prisoners were considered to have lost their civil rights upon incarceration, including the right to challenge disciplinary procedures, as they were legally in the hands of the state. This perspective began to change with landmark court cases that recognized certain rights of prisoners.

Until the 1970s, Disciplinary Procedures Conducted in Prisons Could Be