Turner v. Safley

1987-06-01

Headline: Prison rules mostly upheld: Court affirms ban on cross-institution inmate mail but blocks a near-total rule letting wardens prevent inmates from marrying, changing who controls these personal rights.

Holding: The Court applied a deferential test requiring prison rules be reasonably related to prison security and administration, upheld the cross-institution inmate mail restriction, and struck down the near-total inmate marriage ban.

Real World Impact:

Allows prisons to bar inmate-to-inmate mail across institutions for security reasons.
Stops prison superintendents from broadly banning inmate marriages without narrow justification.
Remands how the mail rule was applied at Renz for further review.

Topics: prison rules, inmate mail, right to marry, prison security

Summary

Background

A group of inmates at a Missouri prison and others who wanted to marry or correspond with inmates sued after statewide rules limited inmate-to-inmate mail and required a superintendent’s permission for marriages, usually allowed only for pregnancy or a newborn. The dispute centered on practices at Renz Correctional Institution, a mixed-security facility used for protective custody, where the rule was effectively applied as a ban on nonfamily mail. The district court and the court of appeals struck down both rules under a strict-review test, prompting Supreme Court review.

Reasoning

The Court asked what test should apply when prison rules limit fundamental rights. It held that courts should be deferential and ask whether a rule is reasonably related to legitimate prison security and administration, rather than applying the most demanding review. Using that standard, the Court found the mail restriction reasonably tied to security concerns (gangs, escape plans, and protecting inmates and staff), so it upheld the correspondence rule. By contrast, the marriage regulation was declared an exaggerated, overbroad response: marriage remains a protected interest, the rule swept too broadly (including civilian spouses), and easy, less restrictive alternatives existed, so the Court invalidated the blanket marriage prohibition.

Real world impact

Prisons may continue to limit inmate-to-inmate correspondence across institutions when officials reasonably show security risks, but they cannot enforce a near-total ban on inmates’ marriages without narrow justification. The Court remanded questions about whether the mail rule was applied arbitrarily at Renz for further review, so some factual issues remain to be decided.

Dissents or concurrances

A separate opinion agreed with invalidating the marriage rule but disagreed with upholding the mail ban, warning the Court adopted an overly deferential standard and improperly reweighed factual findings from the trial court.