OCTOBER TERM, 2000
Syllabus
certiorari to the united states court of appeals for the ninth circuit
No. 99-1613. Argued January 16, 2001—Decided April 18, 2001
While respondent Murphy was incarcerated in state prison, he learned that a fellow inmate had been charged with assaulting a correctional officer. Murphy decided to assist the inmate with his defense and sent him a letter, which was intercepted in accordance with prison policy. Based on the letter's content, the prison sanctioned Murphy for violating prison rules prohibiting insolence and interfering with due process hearings. Murphy then sought declaratory and injunctive relief under 42 U. S. C. § 1983, alleging that the disciplinary action violated, inter alia, his First Amendment rights, including the right to provide legal assistance to other inmates. In granting petitioners summary judgment, the District Court applied the decision in Turner v. Safley, 482 U. S. 78, 89—that a prison regulation impinging on inmates' constitutional rights is valid if it is reasonably related to legitimate penological interests—and found a valid, rational connection between the inmate correspondence policy and the objectives of prison order, security, and inmate rehabilitation. The Ninth Circuit reversed, finding that inmates have a First Amendment right to give legal assistance to other inmates and that this right affected the Turner analysis.
Held:
1. Inmates do not possess a special First Amendment right to provide legal assistance to fellow inmates that enhances the protections otherwise available under Turner. Prisoners' constitutional rights are more limited in scope than the constitutional rights held by individuals in society at large. For instance, some First Amendment rights are simply inconsistent with the corrections system's "legitimate peno-logical objectives," Pell v. Procunier, 417 U. S. 817, 822, and thus this Court has sustained restrictions on, e. g., inmate-to-inmate written correspondence, Turner, supra, at 93. Moreover, because courts are ill equipped to deal with the complex and intractable problems of prisons, Procunier v. Martinez, 416 U. S. 396, 404-405, this Court has generally deferred to prison officials' judgment in upholding such regulations against constitutional challenge. Turner reflects this understanding, setting a unitary, deferential standard for reviewing prisoners' claims that does not permit an increase in the constitutional protection whenever a prisoner's communication includes legal advice. To increase
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