[6] 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.

[6] This did not make much difference at Renz, as the superintendent continued to deny permission to female inmates in most cases, stating that it was not in their "best interest.

"[6] As the end of Safley's sentence grew near, and he was transferred to a halfway house, he tried to visit Watson, but was denied permission when he arrived at Renz.

[6] In 1981, they filed a lawsuit in the Western District of Missouri challenging the constitutionality of the restrictions on inmate mail, marriage, and visitation.

[5] This rendered their individual claim about the marriage restriction moot, but the case was certified as a class action and continued.

The rationale offered by MODOC witnesses for the mail rule was discouraging the formation of inmate gangs, and preventing coordination of riots, escapes, etc.

[6] In his findings of fact, the judge found that the superintendent, out of an apparent "protective attitude", denied permission for female inmates to marry except where there was a birth or a pregnancy.

It spent very little time discussing the "clearly erroneous" argument, simply noting that after reviewing the "entire record," they found "substantial evidence to support each finding of fact.

"[8] With respect to the mail rule, MODOC argued that that plaintiffs' status as inmates meant that the regulation should be review under a rational basis standard, rather than strict scrutiny.

[8] In contrast, an 8th Circuit case, Gregory v. Auger,[13] had treated restriction on inmate mail as "a serious infringement of First Amendment liberties.

[8] Writing for a five-justice majority, Justice Sandra Day O'Connor began by examining the precedent set by Procunier v. Martinez, and determining the appropriate level of scrutiny for judicial review of prison regulations.

"[1] Thus, there were competing interests of justice, and O'Connor argued that courts should tread carefully: Running a prison is an inordinately difficult undertaking that requires expertise, planning, and the commitment of resources, all of which are peculiarly within the province of the legislative and executive branches of government.

Prison administration is, moreover, a task that has been committed to the responsibility of those branches, and separation of powers concerns counsel a policy of judicial restraint.O'Connor wrote that Martinez had not actually formulated a standard of review, and the lower courts had been incorrect to interpret it as imposing strict scrutiny in this case.

[1] Rather, Martinez had imposed strict scrutiny in a situation where inmate mail had been censored based on its content (mail was censored for statements that "unduly complain," "magnify grievances," or express "inflammatory political, racial, religious or other views"), and where the rights of non-inmates were also implicated.

For the second factor, the Court said that inmates still had other forms of expression available, implicitly stating the ability to send and receive mail should not be considered in isolation.

[1] Moreover, while the Court did not deem this fact to be necessary for its holding, it did observe that this "rehabilitation" rationale was based on a suspect classification, as it only applied only to women, in a system of "excessive paternalism.

if the standard can be satisfied by nothing more than a "logical connection" between the regulation and any legitimate penological concern perceived by a cautious warden, .

He cited the original complaint and evidence from trial that discussed the ways that Renz's rules were different from every other facility in Missouri, and only paid lip service to some aspects of MODOC's state-wide standards.

[1] The majority, however, dealt only with MODOC's rules on their face, which clearly did not reflect the situation that had caused the plaintiffs to file their complaint.

Stevens also took issue with the way the majority handled the factual record of the case, with several assertions of fact (such as the gang problems, the availability of other means of expression, and the cost of reading all inmate mail) lacking "a sufficient basis in the record to support the Court's holding on the mail regulation.

I do suggest that consistent application of the Court's reasoning necessarily leads to a finding that the mail regulation applied at Renz is unconstitutional.Turner has been cited as precedent and is now considered to be part of a line of cases like Loving v. Virginia, Zablocki v. Redhail, and Obergefell v. Hodges, in which the Court has declared a fundamental right to marriage under the Fourteenth Amendment.