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Criminal conviction and lawful imprisonment deprive citizens of their freedom and other constitutional rights,2729 but prisoners retain constitutional rights compatible with the objectives of incarceration.2730 Federal courts are reluctant to interfere with the internal administration of prisons,2731 and the judiciary accords wide-ranging deference to the "expert judgment" of prison officials.2732
A prison regulation that infringes on a prisoner's constitutional rights is valid only if it is reasonably related to legitimate penal interests.2733 In determining the reason ableness of a prison regulation, courts should consider: (1) whether a "valid, rational connection" exists between the regulation and the legitimate interest advanced to justify it; (2) whether alternative means for exercising the asserted right remain available; (3) whether accommodation of the asserted right will adversely affect guards, other inmates, and the allocation of prison resources generally; and (4) whether an obvious alternative to the regulation exists "that fully accommodates the prisoner's right at de minimis cost to valid penological interests"2734 . . . . The Supreme Court has rejected a "least restrictive alternative" test in assessing the constitutionality of prison regulations.2735 However, the existence of alternatives may be evidence that the regulation is an unreasonable, "exaggerated response" to prison concerns.2736
SUBSTANTIVE RIGHTS RETAINED BY PRISONERS
Right of Access to Courts. The Constitution guarantees prisoners the right of meaningful access to the courts,2737 and prison officials may not retaliate against prisoners who exercise that right. The Supreme Court has held that the right of access imposes an affirmative duty on prison officials to assist inmates in preparing and filing legal papers, either by establishing an adequate law library or by providing adequate assistance from persons trained in the law.2738 Prison officials are not required to provide both, as long as access to either the library or the trained personnel is "meaningful."2739 Prisoners must demonstrate actual injury resulting from a denial of access to courts in order to allege a constitutional violation.2740 The judiciary recognizes that prisoners face practical difficulties in exercising their right of legal access, and courts relax procedural hurdles in some circumstances to permit prisoners to file and prosecute claims.2741
Courts will allow some restrictions on a prisoner's access to legal resources to accommodate legitimate administrative concerns, such as maintaining security and internal order,2742 preventing the introduction...