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