Jones v. N.C. Prisoners' Labor Union, Inc., 433 U.S. 119 (1977), denied inmates the right to form a prisoners' labor union. The Supreme Court held that, because a labor union's primary purpose is to entertain grievances against prison officials, allowing prisoners to form a labor union would encourage adversarial and combative relations with institution officials and would thus likely increase violence. Id. The Court held that the interest in preserving order and authority in the prisons is self-evident. Prison life, and the relations between the inmates themselves and between the inmates and prison officials or staff, contain the ever-present potential for violent confrontation and conflagration.