Turner v. Safley, 482 U.S. 78 (1987), was a U.S. Supreme Court decision involving the constitutionality of two Missouri prison regulations. One of the prisoners' claims related to the fundamental right to marry, and the other related to freedom of speech (in sending/receiving letters). The court held that a regulation preventing inmates from marrying without permission violated their constitutional right to marry because it was not logically related to a legitimate penological concern, but a prohibition on inmate-to-inmate correspondence was justified by prison security needs.
The case has been cited as precedent, establishing the "Turner Test" for constitutional challenges to prison regulations. According to the test, a prison regulation is constitutional if it satisfies four factors:
- There is a rational connection to a legitimate government interest;
- There are alternative means for prisoners to exercise their right(s);
- Accommodation of the right(s) would have excessive "ripple effects"; and
- There are no "ready alternatives."
This test has been used for decades by US courts, but it has also been criticized by legal scholars for being too deferential to prison administrators. It was there that two inmates, a man named Leonard Safley and a woman named Pearl Jane "P.J." Watson, met and began a relationship. There was an unwritten rule at the time that if two inmates developed a "close" or "physical" relationship, one would be transferred to another facility. After an incident that the trial court would describe as "a noisy lover's quarrel," Safley was transferred to the Ozark Correctional Center at Fordland, Missouri. A five-day trial was held in February 1984, and in May 1984 a ruling was issued that overturned the restrictions on mail and marriage, but left the visitation rule intact. As visitation was not nearly as important a right as the rights of marriage and free speech, the visitation rule was upheld "as a matter of legitimate discretion." Sachs noted that in Procunier v. Martinez the Supreme Court had refrained from crafting a specific standard for mail between inmates, but after discussing various other opinions by appellate courts, he ruled that the mail regulations were "unnecessarily sweeping", and were therefore unconstitutional. and Bell v. Wolfish, etc.), or as barely affecting freedom of speech (as with Jones v. North Carolina Prisoners' Labor Union). had treated restriction on inmate mail as "a serious infringement of First Amendment liberties."