Turner v. Safley (1986)
- Docket
- 85-1384
- Decided
- 1986-01-01
Summary
Question: 1. Was the Missouri Department of Corrections’ restriction limiting correspondence between inmates a violation of those prisoners’ First Amendment rights? 2. Was the Missouri Department of Corrections' restriction limiting prisoners’ ability to marry a violation of prisoners’ constitutional right to marry? Conclusion: No and yes. In a 5-4 decision written by Justice Sandra Day O’Connor and joined by Chief Justice William Rehnquist, Justice Byron White, Justice Louis Powell and Justice Antonin Scalia, the Court upheld the Missouri Department of Correction’s restriction on correspondence between inmates. Justice O’Connor looked to the Court’s test for determining the reasonableness of restrictions on prison inmates’ expressive freedom. She argued that this particular content-neutral restriction on correspondence between inmates was logically connected to the DoC’s legitimate security concerns, noting the danger of coordinated gang activity in Missouri prisons. Justice O’Connor further reasoned that the restrictions did not deprive inmates of all means of expression, only limiting correspondence with a particular class of people. She argued that the Eighth Circuit failed to consider the impact easing the restriction might have on the liberty and safety of prison guards and other inmates. Finally, Justice O’Connor argued that there were no obvious, easy alternatives to the DoC’s restrictions. Turning to the DoC’s marriage restriction, Justice O’Connor held that it was an unconstitutional violation of inmates’ fundamental right to marry. While acknowledging that prisoners’ right to marry is subject to restriction, she argued that many important aspects of marriage should not be altered by a person’s incarceration, including the potential emotional and religious impact of marriage to another. Hence, Missouri prisoners retained a constitutionally-protected right to marry. Justice O’Connor further held that the DoC’s marriage restriction was not reasonably related to its stated interest in preventing violence in prisons and in the rehabilitation of female prisoners. Justice John Paul Stevens, joined by Justices William Brennan, Thurgood Marshall, and Harry Blackmun, concurred in part and dissented in part. While agreeing with the majority’s holding that the marriage restriction was unconstitutional, he rejected the majority’s application of a reasonableness standard to the facts on record. Justice Stevens argued that the majority improperly accepted the DoC’s mostly speculative arguments with respect to the DoC’s security concerns about inmate correspondence, while rejecting the DoC’s similarly speculative concerns about marriage between inmates.