Turner v. Safley

Turner v. Safley was a landmark United States Supreme Court case that addressed the constitutionality of prison regulations restricting freedom of speech and freedom of association of prisoners. The case involved a challenge to Missouri prison regulations that prohibited inmates from corresponding with each other. The Supreme Court ultimately established a new standard for evaluating the constitutionality of prison regulations.

Background

In 1982, Charles Turner and other Missouri prisoners filed a lawsuit against Michael Safley, the Missouri Department of Corrections's superintendent, challenging the constitutionality of a prison regulation that prohibited inmates from corresponding with each other. The prisoners claimed that the regulation infringed on their First Amendment rights to freedom of speech and freedom of association. The United States District Court for the Western District of Missouri initially ruled in favor of the prisoners, but the United States Court of Appeals for the Eighth Circuit reversed the decision.

Supreme Court decision

The United States Supreme Court granted certiorari and heard oral arguments in 1987. In a 5-4 decision, the Court ruled that the prison regulation was unconstitutional because it infringed on the prisoners' First Amendment rights. The majority opinion, written by Justice Sandra Day O'Connor, held that prison regulations restricting freedom of speech and freedom of association must be evaluated under a rational basis test.

Legal test established

The Court established a four-part test, now known as the Turner test, to evaluate the constitutionality of prison regulations restricting freedom of speech and freedom of association. The test requires that:

1. there be a valid, rational connection between the prison regulation and the legitimate governmental interest put forward to justify it; 2. there be no alternative means of exercising the right that remain open to prisoners; 3. the impact of the regulation on prison resources or prison safety be considered; and 4. there be no ready alternatives to the regulation that would achieve the same governmental objectives.

Impact and legacy

The Turner v. Safley decision has had a significant impact on prison law and the rights of prisoners. The Turner test has been applied in numerous cases to evaluate the constitutionality of prison regulations restricting freedom of speech and freedom of association. The decision has also been cited in cases involving prison overcrowding, prison conditions, and prisoner rights. The ruling has been seen as a significant expansion of prisoners' rights and has influenced the development of prison law in the United States. Justice William Brennan, Justice John Paul Stevens, and Justice Thurgood Marshall also played important roles in shaping prison law through their opinions in Turner v. Safley.