Smith v. State

TERNUS, Justice.

This case presents a narrow issue concerning prison discipline: Must a correctional officer’s verbal order to an inmate be based upon a written rule, regulation or procedure in order to provide a valid basis to discipline an inmate who refuses to obey the verbal order? Although the district court held that conduct forbidden by a verbal order must violate a rule, regulation or procedure, we disagree and consequently reverse.

Appellee, Duane Smith, is an inmate of the Iowa State Penitentiary. Correctional officer Putnam observed Smith wearing a religious medallion. Putnam checked…