## Facts

- Missouri inmates brought a class action challenging two prison regulations.
- One regulation restricted inmate-to-inmate correspondence across institutions, allowing it only for immediate family, legal matters, or when both inmates’ classification/treatment teams approved as in the inmates’ best interests.
- A second regulation permitted inmate marriage only with the prison superintendent’s permission and only for “compelling reasons,” which in practice generally meant pregnancy or the birth of an illegitimate child.
- The correspondence and marriage restrictions affected inmates seeking to communicate with, and marry, other incarcerated persons.
- The district court applied strict scrutiny, held both regulations unconstitutional, and the Eighth Circuit affirmed.

## Issues

1. What standard governs constitutional challenges to prison regulations that burden inmates’ rights.
2. Whether the inmate-to-inmate correspondence restriction violated the First Amendment.
3. Whether the marriage restriction violated the constitutional right to marry under the Fourteenth Amendment.

## Decision

- The Supreme Court rejected strict scrutiny as the general standard for prison-regulation challenges and adopted a deferential reasonableness inquiry.
- The Court upheld the inmate-to-inmate correspondence regulation as reasonably related to legitimate penological interests, particularly institutional security.
- The Court invalidated the marriage regulation because the “compelling reasons” requirement and superintendent-permission scheme were not reasonably related to legitimate penological objectives and largely foreclosed marriage.
- Justice O’Connor authored the Court’s opinion; the correspondence ruling was effectively 5–4, and the marriage ruling was effectively unanimous in result.

## Legal Principles

- When a prison regulation impinges on inmates’ constitutional rights, it is valid if it is reasonably related to legitimate penological interests.
- Reasonableness is assessed using four considerations:
  - A valid, rational connection between the regulation and the asserted governmental interest.
  - Whether inmates retain alternative means to exercise the right.
  - The impact that accommodation would have on guards, other inmates, and prison resources.
  - Whether the regulation reflects an exaggerated response, shown by obvious, easy alternatives at de minimis cost to penological interests.
- Restrictions justified by security concerns may be upheld where the record supports a logical connection to preventing coordination of misconduct.
- Regulations that impose a severe, near-total burden on the right to marry require a non-exaggerated, rational relation to legitimate penological goals; broad permission schemes lacking such a relation are unconstitutional.

## Conclusion

The Court established a deferential reasonableness framework for evaluating prison regulations that burden constitutional rights, upheld Missouri’s limits on inmate-to-inmate correspondence based on security concerns, and struck down Missouri’s restrictive inmate-marriage rule because it largely barred marriage without a sufficient rational connection to legitimate penological objectives.


Turner v. Safley, 482 U.S. 78 (1987)