Turner v. Safley

Brief Fact Summary.

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.

Synopsis of Rule of Law.

The reason for the rule did not have a reasonable relationship to the goals of the penal system, therefore the prisoner’s constitutional right to marriage was violated.

Facts.

The Missouri Division of Corrections had regulations permitting inmates to marry only with the permission of the superintendent of the prison, and allowing for such approval only when there are compelling reasons to do so. Prison officials testified that generally only a pregnancy or the birth of an illegitimate child where considered compelling. Plaintiff inmates brought a class action suit for injunctive relief and damages.

Issue.

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

If the rule burdens prisoner’s constitutional rights, should the restriction be tested under a reasonableness standard?

Held.

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.

Prison inmates retain those constitutional rights not inconsistent with their status as a prisoner or with legitimate penological objectives. Although the right to marry is subject to substantial restriction for prisoners, the expressions of emotional support and public commitment; the religious spiritual significance; and the expectation that most inmate marriages will ultimately be consummated remain unaffected by confinement or legitimate correctional goals.

Petitioners rely on security and rehabilitation as their support for the reasonable relationship between the rule and correctional goals. This is because marriages can lead to violent love triangles and the domination of female prisoners who are overly dependant on male figures. However, love triangles can develop without marriage, and the focus on banning mainly the female prisoners from marriage is unacceptable. The almost complete ban on such marriages is overly broad and not reasonably related to legitimate penological objectives.

Discussion.

The Court did not reach the question of if a higher standard of scrutiny is necessary because it found that the rule did not pass muster under the reasonable relationship test. However, the Court did state that the regulation may impose an unacceptable constitutional restriction on non-prisoners because they would be unable to marry incarcerated individuals.