The following excerpt is from Avery v. Elia, No. 2:11-cv-3341 JAM CKD P (E.D. Cal. 2016):
Inmates retain the protections afforded by the First Amendment. O'Lone v. Estate of Shabazz, 482 U.S. 342, 348 (1987). However, the circumstances of incarceration provide a justification for limitation of those rights. Id.
When a prison regulation impinges upon an inmate's First Amendment rights, the regulation will be deemed valid as long as "it is reasonably related to legitimate penological interests." Turner v. Safley, 482 U.S. 78, 79 (1987). There are four factors courts must consider in determining whether a prison regulation is reasonably related to legitimate penological interests:
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