Tuesday, March 5, 2013

Turner v. Safley case brief

Turner v. Safley case brief summary
482 U.S. 78 (1987)

SYNOPSIS: The United States Court of Appeals for the Eighth Circuit affirmed a district court's opinion and order finding unconstitutional regulations governing inmate-to-inmate correspondence and inmate marriages promulgated by petitioner prison system. The prison system sought certiorari review.

OVERVIEW: The district court certified respondents as a class that included inmates at one particular prison who desired to correspond with inmates at other state prisons, and persons who desired to marry inmates of the prison system.
-The correspondence regulation restricted correspondence between inmates in different prisons.
-The marriage regulation permitted inmates to marry only with permission of the prison superintendent, whose approval would be given only for compelling reasons.
-The district court applied a strict scrutiny standard in invalidating the regulations.

-On certiorari review, the Court held that a lesser standard of scrutiny, the reasonable relationship standard, applied to the regulations.

-Applying that standard, the Court concluded that the correspondence regulation was reasonably related to legitimate security interests, while the marriage regulation did not satisfy the reasonable relationship standard because it was an exaggerated response to rehabilitation and security concerns and there were obvious, easy alternatives to the regulation.
-Hence, the Court upheld the validity of the correspondence regulation, but held that the marriage regulation could not be sustained.

OUTCOME: The Court affirmed the lower appellate court's holding striking down the marriage regulation, reversed its holding that the correspondence regulation was unconstitutional, and remanded for consideration of whether the correspondence regulation had been applied in an arbitrary and capricious manner.

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