IN JONES V. NORTH CAROLINA PRISONERS' LABOR UNION, INMATES CHALLENGED A PRISON REGULATION PROHIBITING THE UNION ACTIVITIES NOTED ABOVE. (UNIONS PER SE WERE NOT PROHIBITED.) A FEDERAL DISTRICT COURT FOUND IN FAVOR OF THE INMATES, BUT THE SUPREME COURT REVERSED THAT DECISION, REASONING THAT THE INMATES' FREE SPEECH AND ASSEMBLY RIGHTS HAD NOT BEEN VIOLATED BECAUSE SUCH LIBERTIES ARE NECESSARILY CIRCUMSCRIBED BY CONFINEMENT. THE COURT DETERMINED THAT THE PRISON REGULATION AT ISSUED WAS RELATED RATIONALLY TO THE OBJECTIVE OF PRISON SECURITY AND REPRESENTED NO CONSTITUTIONAL INFRACTION. THE COURT HELD THAT SOLICITATION AS AN INVITATION TO ENGAGE IN A LEGITIMATELY PROHIBITED ACTIVITY MAY BE CURTAILED, THAT AASSOCIATIONAL RIGHTS THREATENING PRISON SECURITY MAY BE DENIED, AND THAT BULK MAILING RATES ARE NOT A RIGHT GUARANTEED BYY THE FIRST AMENDMENT. BY DEFERRING TO ADMINISTRATIVE DISCRETION IN ITS DECISION, THE COURT RESURRECTED THE 'HANDS OFF' DOCTRINE THAT ONCE LIMITED JUDICAIL INTERVENTION IN CORRECTIONS ADMINISTRATION. THE COURT RELIED EXCLUSIVELY ON PRISON ADMINISTRATORS' TESTIMONY AND DID NOT EXAMINE THE FACTS UNDERLYING THE CASE, INCLUDING THE QUESTIONS OF WHETHER INMATES HAVE EFFECTIVE GRIEVANCE MECHANISMS OTHER THAN UNIONS AVAILABLE TO THEM, AND WHETHER INMATE UNIONS ACTUALLY CONSTITUTE A THREAT TO INSTITUTIONAL SECURITY. THERE ARE REASONS TO BELIEVE THAT ESTABLISHED GRIEVANCE MECHANISMS (COMPLAINT BOXES, OMBUDSMAN PROGRMAS, INMATE COUNCILS) ARE NOT ENTIRELY ADEQUATE AND THAT INMATE UNIONS PROMOTE REHABILITATION RATHER THAN THREATEN SECURITY. YET PURSUANT TO THE JONES DECISION, INMATES WILL HAVE NO DEFENSE IF PRISON ADMINISTRATORS CHOOSE TO FORBID THE EXISTENCE OF