Johnson v. California: Possible Equal Protection Standards (to evaluate racial discrimination in the prison context)

Strict Scrutiny:

Is the classification narrowly tailored to further a compelling governmental interest?

Turner standard (deferential review):

Is the regulation reasonably related to legitimate penological interests?

This standard considers 4 factors:

1) Is the policy reasonably related to a legitimate penological interest?
2) Are there alternative means available to exercise the restricted right?
3) Would the accommodation sought significantly impact prison personnel, other inmates, and the allocation of prison resources?
4) Are there obvious, easy alternatives to the prison policy?