Also known as: legitimate penological interests · penological interest
Written by attorneys — see sources below.
A governmental objective such as institutional security, order, or rehabilitation that supports the validity of a prison regulation restricting inmates' constitutional rights when the regulation bears a reasonable relationship to that objective.
Leah Lamb, an inmate, sought to marry her visiting partner. The superintendent required prior approval and denied the request without citing any security or rehabilitation concern. The court applied the reasonable-relationship test and struck down the rule because it lacked any connection to a legitimate penological interest.
Landon Long, a mentally ill inmate, refused antipsychotic medication. Prison doctors administered the drugs under a policy requiring treatment when an inmate posed a danger to self or others. The court upheld the policy because it was reasonably related to the legitimate penological interest in maintaining safety and order.
In August 1976 Walter Harper was sentenced to prison for robbery and incarcerated at the Washington State Penitentiary, where he spent most of his time in the mental health unit and consented to antipsychotic medication. In 1980 Harper was paroled on the condition that he participate in psychiatric treatment, which he received at Harborview Medical Center and later at Western State Hospital under a civil commitment order. His parole was revoked in December 1981 after he assaulted two nurses at a hospital in Seattle. Upon his return to prison, respondent was sent to the Special Offender Center, a 144-bed correctional institute established by the Washington Department of Corrections to diagnose and treat convicted felons with serious mental disorders. At the Center, Harper was diagnosed with a manic-depressive disorder and initially consented to treatment, including antipsychotic drugs, but in November 1982 he refused further medication. The treating psychiatrist then invoked SOC Policy 600.30 to administer the drugs involuntarily after a committee hearing found that Harper suffered from a mental disorder and posed a likelihood of serious harm to others. Harper was involuntarily medicated for about one year beginning November 23, 1982, then transferred to the Washington State Reformatory in November 1983 where he took no medication and his condition deteriorated, prompting his retransfer to the Center and another involuntary medication approval. He continued receiving the drugs subject to periodic reviews until his transfer to the Washington State Penitentiary in June 1986. In February 1985 Harper filed suit in state court under 42 U.S.C. § 1983 against the State and individual defendants, alleging that the failure to provide a judicial hearing before involuntary administration of antipsychotic medication violated due process and other constitutional provisions. After a bench trial in March 1987 the trial court upheld the policy's procedures as satisfying due process, but the Washington Supreme Court reversed, holding that a judicial hearing with full adversarial protections and proof by clear, cogent, and convincing evidence was required. The United States Supreme Court granted certiorari in 1989 to review the constitutional questions presented by the state court's decision.
View caseLuke Latham, a Black inmate, challenged a policy that assigned cells by race to reduce violence. Prison officials defended the practice as necessary to prevent racial conflict. The court applied strict scrutiny rather than the penological-interest test and required the state to show a compelling interest narrowly tailored to the policy.
The California Department of Corrections houses all new male inmates and inmates transferred from other facilities in reception centers for up to 60 days. During this period, double-cell assignments are based predominantly on race. The CDC has admitted that the chances of an inmate being assigned a cellmate of another race are pretty close to zero percent. The CDC further subdivides prisoners within each racial group, separating Japanese-Americans from Chinese-Americans and Northern California Hispanics from Southern California Hispanics. After the initial period, the rest of the prison facilities are fully integrated, and prisoners may choose their own cellmates. Garrison Johnson, an African-American inmate in CDC custody since 1987, was double-celled with another African-American inmate upon his arrival at Folsom prison in 1987 and each time he was transferred to a new facility. Johnson filed a pro se complaint in the United States District Court for the Central District of California on February 24, 1995, alleging that the CDC's reception-center housing policy violated his right to equal protection under the Fourteenth Amendment. After the complaint was dismissed and reinstated on appeal, Johnson filed a Fourth Amended Complaint on July 5, 2000, seeking damages against former directors Rowland and Gomez and injunctive relief against Director Cambra. Following discovery, the District Court granted summary judgment to the defendants on qualified immunity grounds. The Court of Appeals for the Ninth Circuit affirmed, applying the deferential Turner standard. The Court of Appeals denied Johnson's petition for rehearing en banc. We granted certiorari to decide which standard of review applies. 540 U. S. 1217 (2004).
View caseA prison regulation that restricts an inmate's constitutional rights is valid if it is reasonably related to legitimate penological interests such as security, order, or rehabilitation.
Inmates retain a fundamental right to marry, but a prison may restrict that right when the restriction is reasonably related to legitimate penological interests.
A categorical prohibition on inmate-to-inmate marriage is unconstitutional when the stated concerns about housing or commissary disputes can be addressed through narrower measures that do not destroy the right itself.
No. Conditioning an inmate's ability to marry on a promise never to use the marriage in immigration proceedings is not reasonably related to any legitimate penological interest because the asserted goals concern downstream litigation rather than institutional security or order.
No. A blanket prohibition on marriage or new intimate relationships for participants in a drug-treatment program is invalid when the justification concerns only the integrity of private research data rather than security, order, or rehabilitation.
…now: when a prison regulation impinges on inmates' constitutional rights, the regulation is valid if it is reasonably related to legitimate penological interests. In our view, such a standard is necessary if "prison administrators . . . , and not the courts, [are] to make the difficult judgments concerning institutional operations." Subjecting the…