Does a recitation of the charges in writing need to be recited in writing?

Further, a recitation of the charges orally does not suffice. The notice must be "written ... in order to inform [the inmate] of the charges and to enable him to marshal the facts and prepare a defense." Wolff v. McDonnell, 418 U.S. at 564, 94 S.Ct. at 2979. Finally, Wolff v. McDonnell held that due process also requires that the inmate be given at least a brief period of time after receiving the written notice, no less than 24 hours, to permit him to prepare for the disciplinary hearing. See 418 U.S. at 564, 94 S.Ct. at 2978; see also 7 N.Y.C.R.R. 254.6(a).

Although Wolff v. McDonnell did not state expressly that the inmate must be allowed to retain for 24 hours the written notice given him, we think this requirement is fairly inferred from the requirements that there be advance notice, that it be in writing, and that it be given to the inmate at least 24 hours in advance. All of these requirements are designed to assure the inmate a fair chance to prepare his defenses against the charges. Especially when there are a large number of charges or the charges are complicated, that fair chance is denied if the written charges are quickly taken away from the inmate and he is forced to prepare his defenses based largely on his memory of the factual details alleged and regulatory provisions invoked.