Valoaga v. State

Held that Department of Corrections’ application of preponderance of the evidence standard, rather than clear and convincing evidence standard, in disciplinary proceedings did not violate pretrial inmate’s right to due process. Applying the US Supreme Court’s balancing test laid out in Mathew v. Eldridge, the court found that although a more demanding burden of proof would have lessened risk that inmates were mistakenly punished for infractions they did not commit, the more demanding burden would have increased the risk that violations of prison disciplinary rules went unpunished. Placing the risk of mistake equally on prison administrators and the detainee properly balanced important competing interests, namely the detainee’s interest in avoiding harsher conditions of confinement against the prison’s interest in enforcing rules necessary for maintaining order in a challenging environment.