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Turner v. Safley

Turner v. Safley
Supreme Court of the United States
Argued January 13, 1987
Decided June 1, 1987
Full case nameWilliam R. Turner, Superintendent, Missouri Department of Corrections, et al. v. Leonard Safley, et al.
Docket no.85-1384
Citations482 U.S. 78 (more)
107 S. Ct. 2254; 96 L. Ed. 2d 64; 1987 U.S. LEXIS 2362; 55 U.S.L.W. 4719
ArgumentOral argument
Case history
PriorJudgment in part for plaintiffs, 586 F. Supp. 589 (W.D. Mo. 1984); affirmed, 777 F.2d 1307 (8th Cir. 1985); cert. granted, 476 U.S. 1139 (1986).
Holding
A prison regulation preventing inmates from marrying without permission violated their constitutional right to marry because it was not logically related to a legitimate penological concern; but a prohibition on inmate-to-inmate correspondence was justified by prison security needs and so was permissible under the First Amendment, as applied through the Fourteenth.
Court membership
Chief Justice
William Rehnquist
Associate Justices
William J. Brennan Jr. · Byron White
Thurgood Marshall · Harry Blackmun
Lewis F. Powell Jr. · John P. Stevens
Sandra Day O'Connor · Antonin Scalia
Case opinions
MajorityO'Connor, joined by Rehnquist, White, Powell, Scalia; Brennan, Marshall, Blackmun, Stevens (in part III-B only)
Concur/dissentStevens, joined by Brennan, Marshall, Blackmun
Laws applied
U.S. Const. amends. I, XIV

Turner v. Safley, 482 U.S. 78 (1987), was a U.S. Supreme Court decision involving the constitutionality of two Missouri prison regulations. One of the prisoners' claims related to the fundamental right to marry, and the other related to freedom of speech (in sending/receiving letters). The court held that a regulation preventing inmates from marrying without permission violated their constitutional right to marry because it was not logically related to a legitimate penological concern, but a prohibition on inmate-to-inmate correspondence was justified by prison security needs.[1]

The case has been cited as precedent, establishing the "Turner Test" for constitutional challenges to prison regulations.[2][3] According to the test, a prison regulation is constitutional if it satisfies four factors:

  1. There is a rational connection to a legitimate government interest;
  2. There are alternative means for prisoners to exercise their right(s);
  3. Accommodation of the right(s) would have excessive "ripple effects"; and
  4. There are no "ready alternatives."

This test has been used for decades by US courts, but it has also been criticized by legal scholars for being too deferential to prison administrators.[2][3]

  1. ^ Turner v. Safley, 482 U.S. 78 (1987).
  2. ^ a b Emily Chiang, The Turner Standard: Balancing Constitutional Rights & Government Interests in Prison, 5 UCI L. Forum J. 1 (2007).
  3. ^ a b Tanya Kessler, 'Purgatory Cannot Be Worse than Hell': The First Amendment Rights of Civilly Committed Sex Offenders, 12 N.Y. City L. Rev. 283 (2009).

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