Lomax v. Fiedler

In Lomax v. Fiedler, 204 Wis. 2d 196, 209, 554 N.W.2d 841 (Ct. App. 1996), the Court adopted the "reasonably related" standard when reviewing prison-imposed restrictions on inmates' rights. The Court inquired whether the prison's actions were "reasonably related" to legitimate penological objectives. See id. In deciding upon this standard, Lomax relied upon the United States Supreme Court opinions in Turner v. Safley, 482 U.S. 78 (1987), and Thornburgh v. Abbott, 490 U.S. 401 (1989). See Lomax, 204 Wis. 2d at 201. Lomax noted that while prisoners retain the benefit of their constitutional rights, such rights "must necessarily be limited by considerations relating to '"the inordinately difficult undertaking" that is modern prison administration.'" Lomax, 204 Wis. 2d at 205. This is necessarily so because "the legislature has delegated the task of running the state's prisons to the Department of Corrections, not to the courts." Lomax, 204 Wis. 2d at 205. The courts' sole function is "to determine whether the challenged actions strike a reasonable, constitutionally permissible, balance between the rights of prisoners and legitimate concerns of prison administration and security." Id. And such actions should only be overturned if "they are so remote from, and unconnected to, any legitimate correctional or penological interests as to be arbitrary or irrational." Lomax, 204 Wis. 2d at 222.