Turner v. Safley Case Brief

Why is the case important?

Inmates brought suit over a Missouri Corrections regulation that permitted inmates to marry only with permission of the prison superintendent and allowed for approval only when compelling reasons exist.

Facts of the case

“In the late 1970s, Renz Correctional Institution converted to a “complex prison”. Generally, female prisoners at Renz were medium and maximum security level offenders, while most male inmates were minimum security offenders. Leonard Safley was a male inmate at Renz, and P.J. Watson was a female inmate. They met at Renz, where they became romantically involved

  • Watson was then transferred to Ozark Correctional Center because of this relationship. Prison authorities rebuffed all of Safley’s attempts to directly contact Watson.A Missouri Division of Corrections regulation permitted correspondence between inmates who were immediate family members, but correspondence between inmates who were not family members was only allowed if 1) it related to legal matters or 2) at the discretion of the classification/treatment team of both inmates. Another regulation only permitted inmates to marry with the permission of the prison superintendent, and specified that permission should only be given when there was a compelling reason to do so.The district court certified plaintiffs as a class including inmates at Renz who desired to correspond with inmates at other prison facilities. This class also included persons who wished to marry inmates at Missouri correctional facilities and whose right to marry had been allegedly violated by the DoC. Plaintiffs filed an action against Renz’s Superintendent William Turner and others for injunctive relief and damages. The district court applied strict scrutiny to both DoC restrictions. It held that the restriction on correspondence was overly broad and capriciously applied, and that the marriage restriction violated inmates’ constitutional right to marry. The United States Court of Appeals, Eighth Circuit, affirmed, further holding that neither restriction was the narrowest means of addressing the DoC’s security concerns.”

    Question

    Should a different rule apply in a prison forum that does not include marriage as a constitutionally protected right?

    Answer

    Multiple elements of marriage that are not inconsistent with the status of a prisoner are sufficient to form a constitutionally protected right to marriage. Even under a reasonable relationship test, the marriage regulation does not withstand scrutiny.

    Conclusion

    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.

    • Case Brief: 1987
    • Petitioner: William R. Turner, et al.
    • Respondent: Leonard Safley, et al.
    • Decided by: Rehnquist Court

    Citation: 482 US 78 (1987)
    Argued: Jan 13, 1987
    Decided: Jun 1, 1987
    Granted May 27, 1986