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Case Name Turner v. Safley PC-MO-0004
Docket / Court 81-891 ( W.D. Mo. )
State/Territory Missouri
Case Type(s) Prison Conditions
Case Summary
In 1981, prisoners in Missouri brought a 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 ... read more >
In 1981, prisoners in Missouri brought a 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. The challenged correspondence regulation was applied at Rentz so that inmates were not permitted to correspond with inmates at other correctional institutions who were not family members. The marriage regulation in question allowed an inmate to marry only with 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 only a pregnancy or the birth of an illegitimate child were considered to be compelling reasons.

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. Safley v. Turner, 586 F.Supp. 589 (W.D.Mo. 1984). 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.

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. Safley v. Turner, 777 F.2d 1307 (8th Cir. 1985). The U.S. Supreme Court subsequently granted certiorari on May 27, 1986. Turner v. Safley, 476 U.S. 1139 (1986).

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.

Tom Madison - 04/07/2006


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Issues and Causes of Action
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Issues
Discrimination-basis
Sex discrimination
General
Mail
Type of Facility
Government-run
Causes of Action 42 U.S.C. ยง 1983
Defendant(s) Missouri Division of Corrections
Plaintiff Description prisoners of the State of Missouri
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
Prevailing Party Mixed
Public Int. Lawyer No
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement None on record
Order Duration 1984 - n/a
Case Closing Year n/a
Case Ongoing No
Additional Resources
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Case Studies Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
By: Margo Schlanger (Washington University)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty)
Citation: (1998)
[ Detail ]

Links The Oyez Project, Turner v Safley, 482 U.S. 78 (1987)
www.oyez.org
Posted: Jun. 01, 1987
By: Oyez Project (IIT Chicago-Kent College of Law)
[ Detail ] [ External Link ]

Docket(s)
No docket sheet currently in the collection
General Documents
Memorandum Opinion and Order 05/07/1984 (586 F.Supp. 589) (W.D. Mo.)
PC-MO-0004-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Reported Opinion 11/19/1985 (777 F.2d 1307)
PC-MO-0004-0002.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Memorandum Decision 05/27/1986 (476 U.S. 1139)
PC-MO-0004-0004.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Reported Opinion 06/01/1987 (482 U.S. 78)
PC-MO-0004-0003.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Judges Nichol, Fred Joseph (D.S.D.)
PC-MO-0004-0002
O'Connor, Sandra Day (SCOTUS)
PC-MO-0004-0003
Sachs, Howard Frederic (W.D. Mo.)
PC-MO-0004-0001
Monitors/Masters None on record
Plaintiff's Lawyers Baty, Cecilia G. (Missouri)
PC-MO-0004-0002
Finch, Floyd R. Jr. (Missouri)
PC-MO-0004-0001 | PC-MO-0004-0003
Defendant's Lawyers Herschel, Henry Thomas (Missouri)
PC-MO-0004-0001 | PC-MO-0004-0002 | PC-MO-0004-0003
Other Lawyers None on record

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