legitimate penological objectives

In September 1981, respondent Palmer, an inmate at the Bland Correctional Center in Virginia serving sentences for forgery, uttering, grand larceny, and bank robbery, was subjected to a shakedown search of his prison locker and cell by petitioner Hudson, a correctional officer, and a fellow officer. During the search, the officers discovered a ripped pillowcase in a trash can near Palmer's cell bunk. Charges were brought against Palmer under prison disciplinary procedures for destroying state property. Following a hearing, Palmer was found guilty, ordered to reimburse the state for the destroyed material, and received a reprimand on his prison record. Palmer then filed a pro se action in United States District Court under 42 U.S.C. § 1983. He alleged that Hudson conducted the search and brought the false charge solely to harass him, and that Hudson intentionally destroyed some of his noncontraband personal property, including legal materials and letters, during the search, thereby depriving him of property without due process of law in violation of the Fourteenth Amendment. Hudson denied the allegations and moved for summary judgment, which the District Court granted. The court accepted Palmer's allegations as true but concluded that the destruction of property, even if intentional, did not violate the Fourteenth Amendment because state tort remedies were available, and that the alleged harassment did not rise to a constitutional level. The Court of Appeals for the Fourth Circuit affirmed in part and reversed in part. It affirmed the dismissal of the due process claim regarding property destruction, extending the logic of Parratt v. Taylor to intentional deprivations. However, it reversed the summary judgment on the claim that the shakedown search was unreasonable, holding that an individual prisoner has a limited privacy right in his cell that could be breached by searches conducted solely to harass or humiliate. The court remanded for further proceedings to determine the purpose of the search, noting a factual dispute over whether it was routine or harassing. The Supreme Court granted certiorari in both the main petition and the cross-petition to address the privacy expectation in prison cells and the extension of Parratt to intentional deprivations.

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.

The plaintiffs were four California prison inmates and three professional journalists who sued the Director of the California Department of Corrections and subordinate officers. They challenged the constitutionality under the First and Fourteenth Amendments of section 415.071 of the California Department of Corrections Manual. That section provides that press and other media interviews with specific individual inmates will not be permitted. The regulation was promulgated under authority from section 5058 of the California Penal Code and applies uniformly throughout the state's penal system. Pell, Segal, and Jacobs requested permission to interview specific inmates Spain, Bly, and Guile. The editors of a periodical requested permission to visit inmate Hillery to discuss publishing his writings and to interview him concerning prison conditions. All these requests were denied pursuant to the regulation. The plaintiffs brought suit under 42 U.S.C. § 1983 seeking injunctive and declaratory relief. A three-judge District Court in the Northern District of California was convened. The court granted summary judgment to the inmate plaintiffs, holding that the regulation infringed their constitutional rights. It granted the defendants' motion to dismiss the media plaintiffs' claims. The defendants appealed the judgment regarding the inmates, and the media plaintiffs appealed the rejection of their claims. The Supreme Court noted probable jurisdiction of both appeals and consolidated the cases for argument. The regulation was imposed in 1971 in response to a violent episode at San Quentin State Penitentiary. Officials viewed the episode as the climax of mounting disciplinary problems caused in part by the prior liberal policy on press interviews. Under current corrections policy, both the press and the general public are accorded full opportunities to observe prison conditions. Newsmen are permitted to visit both maximum and minimum security sections, stop and speak to any inmates they encounter, and interview inmates selected at random by corrections officials. However, the regulation prohibits face-to-face interviews with individual inmates specifically designated by the press.