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Turner v. Safley

Supreme Court of the United States · 1987 · Constitutional Law

Constitutional LawPrisoners' RightsFirst AmendmentRight to MarryTurner testreasonable relationshiplegitimate penological interestsprison administration

Facts

Missouri prison regulations allowed inmate correspondence with immediate family members who were inmates and correspondence concerning legal matters, but otherwise permitted inmate-to-inmate correspondence only if both inmates' classification/treatment teams deemed it in their best interests; at Renz, the district court found the rule was practiced as a ban on writing non-family inmates. A separate regulation allowed an inmate to marry only with the superintendent's permission and only when there were 'compelling reasons,' which prison officials testified generally meant pregnancy or the birth of an illegitimate child. Prison officials justified the correspondence restriction on security grounds, including escape plans, assaults, gang activity, and risks to protective custody arrangements. They justified the marriage restriction on security concerns about 'love triangles' and rehabilitation concerns, especially regarding female inmates' dependency on male figures.

Issue

What standard governs constitutional challenges to prison regulations that burden inmates' rights, and under that standard are Missouri's inmate-to-inmate correspondence rule and inmate marriage restriction constitutional? Specifically, the Court had to decide whether strict scrutiny applied or whether a more deferential standard controlled.

Rule

When a prison regulation impinges on inmates' constitutional rights, the regulation is valid if it is reasonably related to legitimate penological interests. Relevant factors include: (1) whether there is a valid, rational connection between the regulation and a legitimate and neutral governmental objective; (2) whether alternative means of exercising the right remain open to inmates; (3) the impact accommodation of the asserted right will have on guards, other inmates, and prison resources; and (4) whether the absence or existence of obvious, easy alternatives shows the regulation is reasonable or instead an exaggerated response. This is not a least restrictive alternative test.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The Red Mesa Correctional Center in New Mexico bars inmates from joining any inmate-run study circles that discuss political theory. Omar Ruiz, an inmate, sues and argues that because the rule burdens speech, the court must apply strict scrutiny and require the prison to adopt the least restrictive means.

What is the strongest response under the governing doctrine?

Explanation. When a prison regulation impinges on inmates' constitutional rights, the governing test is whether the regulation is reasonably related to legitimate penological interests. The Court rejected strict scrutiny and also rejected a least-restrictive-alternative requirement for ordinary prisoners' rights claims, emphasizing judicial deference to prison administrators on institutional operations.