What is the effect of revocation of parole on a parolee?

The revocation of parole certainly condemns the parolee to suffer far more grievous loss than the other matters for which procedural due process has been constitutionally compelled. (See Wisconsin v. Constantineau (1971) 400 U.S. 433, 436--437, 91 S.Ct. 507, 27 L.Ed.2d 515.) The parolee is not merely a prisoner. (See In re Marzec (1945) 25 Cal.2d 794, 797, 154 P.2d 873.) He works at a job, lives with his family, reads books and newspapers of his choosing, enjoys a limited right to travel, makes friends, and generally pursues a normal law-abiding life within the conditions of his parole. (See Note, 84 Harv.L.Rev. (1971) 1727.) When his parole is revoked and he is returned to prison, the parolee loses his precious, albeit limited, freedom. ⁴¹ He loses his job and his ability to lead a relatively normal life. As a result of the parole revocation he may spend the rest of his life in prison. These consequences are sufficiently severe to invoke at least the basic requisites of due process. (See Hester v. Craven (C.D.Cal.1971) 322 F.Supp. 1256, 1261--1265.) In any case, we are not seeking to protect the 'grace' ⁴² or 'right' of parole; we are attempting to express and vindicate the right to a fair determination of the facts upon which the state would deprive a person of parole and his concurrent liberty.

Finally, we must confront an argument which apparently underlies the majority's position:

To grant procedures which comport with due process every time parole is suspended

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