IN JONES V. NORTH CAROLINA THE PRISON ADMINISTRATION SUCCESSFULLY ARGUED THAT THE SECURITY OF THE INSTITUTION WOULD BE ENDANGERED IF THE PRISONERS WERE ALLOWED TO SOLICIT MEMBERS FOR A LABOR UNION OR HOLD UNION MEETINGS. BY SUBORDINATING FIRST AMENDMENT RIGHTS IN ITS DECISION, THE COURT REVERSED ITS RECENT ACTIVE STANCE TOWARDS PROTECTION OF INMATE CONSTITUTIONAL RIGHTS. THE HISTORY OF THIS ACTIVE INTERVENTION IN PRISON REFORM IS TRACED AND THE CHANGES MADE AS THE RESULT OF SUPREME COURT DECISIONS ARE PRAISED. IT IS MAINTAINED THAT THE JONES DECISION WILL HAVE CONSEQUENCES FAR BEYOND THE ISSUE OF UNIONIZATION. BY REFUSING TO REVIEW ADMINISTRATION REGULATIONS THE COURT WILL PERPETUATE THE TYPE OF INSTITUTION WHICH FOSTERS A FEELING OF ALIENATION AMONG INMATES. THE IMPORTANCE OF INMATE ORGANIZATIONS AND FAIR GRIEVANCE PROCEDURES IS EMPHASIZED. IT IS FELT THAT JONES WILL GUARANTEE THE CONTINUATION OF POLICIES WHICH INHIBIT COMMUNICATIONS BETWEEN INMATES AND BETWEEN INMATES AND STAFF. IT IS ALSO ARGUED THAT UNREVIEWED PRISON REGULATIONS RESTRICTING THE AVAILABILITY OF GRIEVANCE MECHANISMS WILL INCREASE HOSTILITY AND VIOLENCE. IT IS CONCLUDED THAT IN JONES THE SUPREME COURT REMOVED ALL DOUBT THAT CUSTODIAL CONCERNS WILL CONTROL THE DIRECTION OF PRISON CONDITIONS FOR YEARS TO COME. THE ARTICLE IS HEAVILY FOOTNOTED. (GLR)