482 U.S. 78 (1987)
Respondents, a class of inmates confined or to be confined at the Renz Correctional Institution, brought this action in the United States District Court for the Western District of Missouri against petitioners, officials of the Missouri Division of Corrections.1 The Renz facility, located in Cedar City, Missouri, housed both male and female prisoners of varying security classifications in a minimum security setting without guard towers or walls.2 Most female prisoners at Renz were medium or maximum security inmates, while most male prisoners were minimum security offenders.3 The facility was occasionally used to provide protective custody for inmates from other Missouri prisons.4
Two regulations were at issue in the litigation.5 The correspondence regulation permitted inmate-to-inmate letters only with immediate family members at other institutions or concerning legal matters, and otherwise only when the classification team of each inmate deemed it in the best interest of the parties.6 As applied at Renz, the rule operated as a complete prohibition on correspondence between non-family inmates.7 The marriage regulation, promulgated while the suit was pending, required the prison superintendent's approval for any inmate marriage and directed that approval be granted only upon a finding of compelling reasons, which officials generally limited to situations involving pregnancy or the birth of an illegitimate child.8
The District Court certified a class encompassing persons confined or to be confined at Renz who wished to correspond with inmates at other Missouri facilities or to marry inmates of Missouri correctional institutions.9 Following a bench trial, the District Court concluded that both regulations violated the inmates' constitutional rights.10 The court applied a strict scrutiny standard derived from prior precedent and determined that the regulations were not the least restrictive means of achieving the state's asserted interests.11 The District Court also found that the correspondence regulation had been enforced in an arbitrary and capricious manner.12
The Court of Appeals for the Eighth Circuit affirmed the District Court's judgment in its entirety.13 The appellate court agreed that strict scrutiny was the proper standard and that neither regulation satisfied that standard.14 The Supreme Court granted certiorari to consider the validity of the regulations.15
Whether the appropriate standard of review for evaluating the constitutionality of prison regulations that impinge on inmates' constitutional rights is strict scrutiny or a reasonableness standard?16
When a prison regulation impinges on inmates' constitutional rights, the regulation is valid if it is reasonably related to legitimate penological interests.17 Several factors are relevant in determining reasonableness.18 (1) There must be a valid, rational connection between the regulation and the legitimate governmental interest.19 (2) Whether there are alternative means of exercising the right that remain open to prison inmates.20 (3) The impact accommodation of the asserted constitutional right will have on guards and other inmates, and on the allocation of prison resources generally.21 (4) The absence of ready alternatives is evidence of the reasonableness of a prison regulation.22
Yes. The Court rejected the strict scrutiny standard applied by the lower courts in favor of the reasonableness standard drawn from Pell, Jones, Bell, and Block.23 In the established facts, the Renz Correctional Institution's unique population mix and use for protective custody support the need for deference to prison officials' judgments on security matters.24 The Court applied this standard to both the correspondence and marriage regulations, finding the former reasonable and the latter not.25
The reasonableness standard is the appropriate standard of review for the prison regulations at issue.26
Related opinions on this issue
Joined by Justice Brennan, Justice Marshall, And Justice Blackmun
Justice Stevens, concurring in part and dissenting in part, argued that the Court's reasonableness standard is virtually meaningless if satisfied by nothing more than a logical connection between the regulation and any legitimate penological concern perceived by a cautious warden.27
Application of the standard would seem to permit disregard for inmates' constitutional rights whenever the imagination of the warden produces a plausible security concern and a deferential trial court is able to discern a logical connection between that concern and the challenged regulation.28 He dissented from the adoption of the standard in Part II of the opinion.29
Justice Stevens concurred in the invalidation of the marriage regulation because the Court's conclusion did not rely on a rejection of a more stringent standard and the justifications lacked record support.30 He dissented from the upholding of the correspondence regulation, arguing that the District Court's findings showed the total ban at Renz was an exaggerated response and that the record did not support the conclusion that screening mail would be impossible or that the ban was necessary.31 The Court of Appeals correctly held that the trial court's findings of fact adequately supported its judgment.32
Whether the Missouri Division of Corrections regulation restricting correspondence between inmates at different institutions is constitutional?33
A prison regulation that impinges on inmates' constitutional rights is valid if it is reasonably related to legitimate penological interests, considering the four factors of rational connection, alternative means, impact on others, and ready alternatives.34
Yes. The correspondence regulation is reasonably related to legitimate security interests.35 The regulation was promulgated primarily for security reasons to prevent escape plans, assaults, and gang activity.36 The Renz facility's role in protective custody would be compromised by allowing such correspondence.37
The regulation does not deprive prisoners of all means of expression, as it allows correspondence with family and legal matters.38 There are no ready alternatives without more than de minimis cost, as monitoring all mail would be burdensome and codes could be used.39
The correspondence regulation is constitutional on its face.40
Related opinions on this issue
Joined by Justice Brennan, Justice Marshall, And Justice Blackmun
Justice Stevens dissented from the upholding of the correspondence regulation.41 He argued that the District Court's findings showed the total ban at Renz was an exaggerated response to the security problems predicted by petitioners' expert witnesses.42 The Court based its holding upon its own highly selective use of factual evidence rather than the trial record.43
Speculation about possible adverse consequences of allowing inmates in different institutions to correspond is found in the testimony of three witnesses, but none of them established that permitting such correspondence would create a security risk at Renz.44 The record does not support the conclusion that screening mail would be impossible or that the ban was necessary, as the staff at Renz has been able to scan and control outgoing and incoming mail, including inmate-to-inmate correspondence.45 The blanket prohibition enforced at Renz is not only an excessive response to any legitimate security concern but is inconsistent with a consensus of expert opinion.46
Whether the Missouri Division of Corrections regulation restricting inmate marriages is constitutional?47
A prison regulation that impinges on inmates' constitutional rights is valid if it is reasonably related to legitimate penological interests, considering the four factors of rational connection, alternative means, impact on others, and ready alternatives. The right to marry is a fundamental right that survives incarceration in a limited form.48
No. The marriage regulation is not reasonably related to legitimate penological interests.49 The regulation prohibits marriages unless there are compelling reasons, generally limited to pregnancy.50 The District Court found it was an exaggerated response to security and rehabilitation concerns.51 There are obvious alternatives like counseling.52 The regulation sweeps too broadly.53 The rehabilitation concern was suspect and based on excessive paternalism toward female inmates.54
The marriage regulation is unconstitutional.55
Related opinions on this issue
Joined by Justice Brennan, Justice Marshall, And Justice Blackmun
Justice Stevens concurred in the invalidation of the marriage regulation.56 The Court's conclusion did not rely on a rejection of a standard of review more stringent than the one announced in Part II.
The Court in Part III-B concludes after careful examination that, even applying a reasonableness standard, the marriage regulation must fail because the justifications asserted on its behalf lack record support.57 He was able to join that part of the opinion because the invalidation does not depend on adopting a stricter standard.58
The contrasts between the Court's acceptance of the challenge to the marriage regulation as overbroad and its rejection of the challenge to the correspondence rule are striking, but he concurs fully in the invalidation of the marriage rule.59