THE CONTINUED VITALITY OF INMATE UNIONS IS BEING THREATENED BY THE 1977 SUPREME COURT DECISION OF JONES VERSUS THE NORTH CAROLINA PRISONERS' LABOR UNION, INC. IN REFUSING TO APPLY THE CONSTITUTIONAL PROTECTION OF THE FIRST AMENDMENT, THE COURT MAY HAVE BROUGHT TO A HALT DEVELOPING TRENDS IN INMATE UNIONS. THE GROWTH AND DEVELOPMENT OF INMATE UNIONS AND PROBABLE REPERCUSSIONS OF THE SUPREME COURT'S DECISION IN THE AREA OF PRISON RIGHTS AND UNION ORGANIZATION ARE DISCUSSED. PARTICULAR ATTENTION IS GIVEN TO THE HANDS-OFF DOCTRINE CONCERNING PRISON RIGHTS, THE LABOR MOVEMENT, AND INMATE ORGANIZATION WITHIN A UNION FRAMEWORK. IT IS ARGUED THAT THE HISTORY OF INMATE ORGANIZING ACTIVITIES IS REPLETE WITH ATTEMPTS TO SECURE BARGAINING STATUS WITH OFFICIAL AUTHORITIES, AND THAT REFUSING TO ALLOW INMATE UNIONS IS EXPECTED TO HINDER THE FURTHER ADVANCEMENT OF PRISONER RIGHTS. FURTHER, THAT IF REHABILITATION IS AN ACTUAL GOAL OF THE PENAL SYSTEM, A HYBRID UNION DESERVES AN OPPORTUNITY TO ESTABLISH ITS CREDENTIALS (OR LACK THEREOF) IN THE CORRECTIONAL SETTING. REFERENCES AND JUDICIAL DECISIONS ARE FOOTNOTED. (DCP)