TURNER v. SAFLEY

Legal Principle at Issue

Whether prisoners' First Amendment rights were violated by two Missouri Division of Corrections regulations banning inmate marriages and inmate-to-inmate correspondence without a "compelling" reason.

Action

Affirmed and reversed (or vacated) in part and remanded. Petitioning party received a favorable disposition.

Facts/Syllabus

Respondents filed a class action challenging Missouri prison regulations on inmate correspondence and marriage, focusing on practices at the Renz Correctional Institution. One regulation restricted correspondence between inmates at different prisons, generally allowing it only for family or legal matters unless approved by prison officials. In practice, the rule effectively barred most non-family inmate correspondence based on officials’ broad discretion. The second regulation required inmates to obtain permission to marry, which was granted only for undefined “compelling reasons,” typically limited to pregnancy or childbirth. The District Court found both regulations unconstitutional, applying strict scrutiny and concluding they unnecessarily restricted constitutional rights. It held that less restrictive alternatives could address security concerns and that the rules were overly broad and arbitrarily applied. The U.S. Court of Appeals for the Eighth Circuit affirmed, agreeing that the regulations were not the least restrictive means of achieving legitimate prison objectives and unjustifiably infringed on inmates’ rights.