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.
The district court certified Safley et al. 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.
Was the correspondence regulation valid?
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.