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Law School Case Brief

Turner v. Safley - 482 U.S. 78, 107 S. Ct. 2254 (1987)


Prison walls do not form a barrier separating prison inmates from the protections of the Constitution. Because prisoners retain these rights, when a prison regulation or practice offends a fundamental constitutional guarantee, federal courts will discharge their duty to protect constitutional rights.


The district court certified respondents as a class that included inmates at one particular prison who desired to correspond with inmates at other state prisons, and persons who desired to marry inmates of the prison system. The correspondence regulation restricted correspondence between inmates in different prisons. The marriage regulation permitted inmates to marry only with permission of the prison superintendent, whose approval would be given only for compelling reasons. The district court applied a strict scrutiny standard in invalidating the regulations. 


Whether prison regulations governing inmate-to-inmate correspondence and inmate marriages promulgated by petitioner prison system were constitutional?


No. The marriage regulation could not be sustained.


On certiorari review, the Court held that a lesser standard of scrutiny, the reasonable relationship standard, applied to the regulations. Applying that standard, the Court concluded that the correspondence regulation was reasonably related to legitimate security interests, while the marriage regulation did not satisfy the reasonable relationship standard because it was an exaggerated response to rehabilitation and security concerns and there were obvious, easy alternatives to the regulation. Hence, the Court upheld the validity of the correspondence regulation, but held that the marriage regulation could not be sustained.

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