When a prison regulation impinges on inmates' constitutional rights, the regulation is valid if it is reasonably related to legitimate penological interests. Such a standard is necessary if prison administrators, and not the courts, are to make the difficult judgments concerning institutional operations.
Respondent inmates brought a class action challenging two regulations promulgated by the Missouri Division of Corrections. The first permitted correspondence between immediate family members who were inmates at different institutions within the Division's jurisdiction, and between inmates "concerning legal matters," but allowed other inmate correspondence only if each inmate's classification/treatment team deemed it in the best interests of the parties. The second regulation permitted an inmate to marry only with the prison superintendent's permission, which could be given only when there were "compelling reasons" to do so. Testimony indicated that generally only a pregnancy or the birth of an illegitimate child would be considered "compelling." The Federal District Court found both regulations unconstitutional, and the Court of Appeals affirmed. Thereafter, the prison system sought certiorari review.
Did the lower courts correctly find the Missouri prison regulations to be unconstitutional?
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.