In re Goalen

Background

Ronald Easthope is an inmate in the Utah State Prison and Ann Goalen is his fiancée; both are legally able and competent to marry under state law. Utah law once suspended many civil rights for people serving prison sentences, and the State Board of Corrections adopted a policy allowing inmates to marry only when they are within six months of release and recommended by a treatment team. The prison warden denied permission because Easthope did not meet the policy’s terms, and Goalen sued in state court seeking an order to allow the marriage. Utah’s courts denied relief and rejected the constitutional challenge.

Reasoning

The central question was whether the freedom to marry applies to someone in prison and, if so, whether Utah’s policy can bar that marriage. The State defended its policy as an incentive tied to rehabilitation and cited no safety or discipline concerns. The highest court dismissed the appeal for lack of jurisdiction and declined to review the state-court decision, so it did not decide the constitutional question. Justice Stewart, joined by Justices Douglas and Brennan, dissented, relying on earlier cases that recognize marriage as a fundamental liberty and arguing the State’s incentive rationale may be insufficient; he would have vacated and sent the case back for further consideration, especially given a recent repeal of the underlying statute.

Real world impact

Because the Court refused review, the Utah Supreme Court’s ruling and the corrections policy remain in effect for now, preventing this inmate from marrying under the State’s rules. The case was not decided on the merits, and a legislative repeal may change the policy’s force on remand.

Dissents or concurrances

Justice Stewart’s dissent, joined by two colleagues, argued the right to marry deserves fuller consideration and urged the state court to reconsider in light of the statute’s repeal.