The following excerpt is from Winson v. Marshall, 108 F.3d 1387 (9th Cir. 1997):
Prisoners have a First Amendment right to receive mail. Witherow v. Paff, 52 F.3d 264, 265 (9th Cir.1995) (per curiam). A prison action that infringes upon an inmate's right to receive mail is valid if the action is " 'reasonably related to legitimate penological interests.' " See O'Keefe, 82 F.3d at 325 (quoting Turner v. Safley, 482 U.S. 78, 89 (1987)). Whether the action is reasonable depends upon whether: (1) the regulation has a logical connection to the legitimate government interests put forth to justify it; (2) alternative means of exercising the asserted right remain open to the inmate; (3) accommodation of the asserted right will impact other inmates, guards, and prison resources; and (4) ready alternatives exist that will fully accommodate the inmate's rights at de minimis cost to the proffered penological interests. See id.
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