The analysis emphasizes that differences in legal systems make it difficult to compare prisoners' rights in England and the United States. However, the European Convention on Human Rights provides a basis for comparison. In all three contexts, the main rights that are claimed rest on notions of inhuman and degrading treatment, involuntary servitude, access to courts and jurisdiction over prison matters, freedom of correspondence, freedom of religion, and property rights. In addition, two similarities between England and the United States are the judicial attitudes toward prisoners' claims and prisoners' rights of access to courts. However, English prisoners have access to a wider range of rights, because American prisoners are limited to Federally protected constitutional rights. Nevertheless, wide differences exist within the prison systems regarding how well prisoners' rights are protected. Finally, in both systems, judges have concentrated largely on procedural issues and have tended to neglect the major issues of substantive justice. Index and 182 references.