Shaw v. Murphy case brief

Shaw v. Murphy case brief summary

532 U.S. 223 (2001)

CASE SYNOPSIS

Petitioner prison officials' petition for writ of certiorari to the United States Court of Appeals for the Ninth Circuit was granted, in a case involving the issue of whether prisoners possessed a First Amendment right to provide legal assistance that enhanced the protections for inmate communications otherwise available under the Turner test.

CASE FACTS
Respondent inmate, a prison law clerk, sued petitioners, alleging they violated his constitutional rights when they disciplined him for statements he made in a letter giving legal advice to another inmate. The court of appeals applied the Turner test, but did so against the backdrop of respondent's First Amendment right, and upheld respondent's First Amendment claim.

DISCUSSION

• The U.S. Supreme Court reversed, holding that inmates did not possess a special First Amendment right to provide legal assistance to fellow inmates. 
• The Turner test concerned only the relationship between the asserted penological interests and the prison regulation, and did not accommodate valuations of content. 
• If courts were permitted to enhance constitutional protection based on their assessments of the content of the particular communications, courts would be in a position to assume a greater role in decisions affecting prison administration. 
• The U.S. Supreme Court rejected an alteration of the Turner test that would have entailed additional federal-court oversight. Accordingly, the judgment of the court of appeals was reversed, and the case was remanded.

CONCLUSION

Judgment was reversed and remanded, since prisoners do not possess a First Amendmentright to provide legal assistance that enhanced the protections otherwise available under the Turner test.