How to Determine If Prison Regulations Are Reasonable ?

In Bundy v. Beard, 924 A.2d 723, 729 (Pa. Cmwlth. 2007), this Court applied the four factors "relevant in determining the reasonableness of the prison regulations" as set forth in Turner v. Safley, 482 U.S. 78, 107 S.Ct. 2254, 2261, 96 L. Ed. 2d 64 (1987), and held that they must be considered before a court declares a prison policy unconstitutional: (1) whether a "valid, rational connection" exists between the prison regulation and a legitimate government interest; (2) whether an alternate "means of exercising the right" remains available; (3) the impact on the prison system; (4) whether a readily available alternative to the policy exists. Bundy, 924 A.2d at 729. A policy is constitutional if it reasonably relates to a legitimate penological interest and is "not an exaggerated response" to achieving that interest. Beard v. Banks, 548 U.S. 521, 126 S. Ct. 2572, 2577-78, 165 L. Ed. 2d 697 (2006).