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Jones v. North Carolina Prisoners' Labor Union, Inc.

433 U.S. 119 (1977)

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Jones v. North Carolina Prisoners’ Labor Union, Inc.

United States Supreme Court
433 U.S. 119 (1977)

Facts

Prisoners in North Carolina prisons began efforts to form a union (the union) (plaintiff) to seek better working conditions in the prison and to try to reform disfavored prison policies. By 1975, the union had 2,000 prisoner members across 40 prisons. The union had not caused any disruptions, and there was no evidence that the prisoners intended to operate the union in a disruptive or unlawful manner. However, the North Carolina Department of Corrections (DOC) (defendant) was concerned that union leaders might gain notable power and would be able to cause future disruptions and safety issues that the prisons would not be able to control. To preemptively guard against this risk, the DOC implemented rules prohibiting (1) a prisoner’s solicitation of other prisoners to join a union, (2) union meetings, and (3) bulk mailings about union matters. The union sued the DOC in federal district court alleging that the rules violated the prisoners’ First Amendment speech, association, and assembly rights. The district court found that there was no evidence that the union posed a present danger to security and order and issued an injunction essentially preventing the prison from enforcing any of the three rules. The DOC appealed directly to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Rehnquist, J.)

Concurrence (Burger, C.J.)

Concurrence/Dissent (Stevens, J.)

Dissent (Marshall, J.)

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