Case: Turner v. Safley

In 1981, prisoners in Missouri brought this class action lawsuit in the U.S. District Court for the Western District of Missouri challenging the constitutionality of Department of Corrections regulations relating to inmate marriages and inmate-to-inmate correspondence. These regulations were alleged to violate the prisoners' First Amendment rights and their fundamental human right to enter into a marital relationship. Although the challenged regulations were in effect throughout Missouri, this litigation focused on practices at the Renz Correctional Institution (Renz) in Cedar City, Missouri, which houses both male and female prisoners. As applied at Renz, the regulation forbade inmates from corresponding with inmates at other correctional institutions who were not family members. The regulations also prohibited inmates from marrying without the permission of the superintendent of the prison and provided that such permission should be given only when there were compelling reasons to do so. Generally, compelling reasons were limited to pregnancy or the birth of an illegitimate child.

On May 7, 1984, the District Court (Judge Howard F. Sachs) found both the correspondence and marriage regulations unconstitutional by applying a strict scrutiny standard. 586 F. Supp. 589. The Court held the marriage regulation to be an unconstitutional infringement upon the fundamental right to marry because it was far more restrictive than was either reasonable or essential for the protection of the State's interests in security and rehabilitation. The Court also found the correspondence regulation to be unnecessarily broad because prison officials could effectively cope with the security problems raised by inmate-to-inmate correspondence through less restrictive means, such as scanning the mail of potentially troublesome inmates.

The defendants appealed the decision and on November 19, 1985, the U.S. Court of Appeals for the Eighth Circuit (Senior District Judge Fred Joseph Nichol, sitting by designation) affirmed by holding that the District Court properly used strict scrutiny in evaluating the constitutionality of the Missouri correspondence and marriage regulations. 777 F.2d 1307. The U.S. Supreme Court subsequently granted certiorari on May 27, 1986. 476 U.S. 1139.

On June 1, 1987, the Supreme Court (Justice Sandra Day O'Connor) affirmed in part, reversed in part, and remanded the case. Turner v. Safley, 482 U.S. 78 (1987). The Supreme Court held that a lesser standard of review than the strict scrutiny standard is appropriate for resolving prisoners' constitutional claims against prison regulations. Such cases require an inquiry into whether a prison regulation that impinges upon inmates' constitutional rights is ""reasonably related"" to legitimate penological interests. In this case, the Supreme Court held that the inmate marriage regulation was not reasonably related to any legitimate penological objective. However, the Court did find that the inmate-to-inmate correspondence rule was reasonably related to legitimate security concerns of prison officials so as not to be facially invalid. Justice John Paul Stevens concurred in part and dissented in part and filed an opinion in which Justices Brennan, Marshall and Blackmun joined. In his opinion, Justice Stevens argued that constitutional recognition and protection should be extended to the right to communicate (covering the correspondence regulation at issue) as well as the right to marry.

The docket for this case was not available on PACER, and accordingly, we do not have further information on the case.