In two court cases, inmates have been told that they do not have a right to smoke in certain situations within the prison system; although non-smoking inmates have not won explicit rulings that they have a right to avoid the smoke of other inmates, the case law acknowledges that this is an emerging issue. Two cases do suggest that inmates have the right to be free from "environmental tobacco smoke." Several other cases appear to forewarn of future decisions that may demand more rigorous protection of inmates from secondhand smoke as the "evolving standards of decency that mark the progress of society" require provision of a smoke-free environment within the prison setting.