Eighth Circuit -- Michael Persechini v. L. Callaway

Michael Persechini v. L. Callaway

Prisoner S1983 claim alleging that his transfer from early-parole drug treatment facility as a result of alleged towel theft (he claims he was just 'trading up') violated Due Process.

Held: Inmate did not have a protected liberty interest in the prospect of early parole after completion of the program.

No liberty interest, as only consequence is that inmate has to serve out his initial term.