PRISON CONTROL, WHICH USED TO BE CONCENTRATED AND HIERARCHICAL, HAS COME TO BE CONTESTED BY A WIDE ASSORTMENT OF ACTORS: THE CORRECTIONS COMMISSIONER AND HIS STAFF; THE PRISON WARDEN; THE CUSTODIAL FORCE; OFFICIALS OF WATCHDOG AGENCIES RESPONSIBLE FOR MONITORING PRISON CONDITIONS; REPRESENTATIVES OF THE LEGISLATIVE, EXECUTIVE, AND JUDICIAL BRANCHES; ACTIVISTS FROM SPECIAL INTEREST GROUPS; AND THE PRISONERS THEMSELVES. BEFORE THE 1960'S THE JUDICIARY GENERALLY FOLLOWED A HANDS-OFF POLICY WITH REGARD TO CORRECTIONS, LEAVING PRISON SECURITY AND INMATE CONDITIONS TO THE DISCRETION OF THE CORRECTIONAL STAFF. HOWEVER, SINCE THE EARLY 1960'S, THE COURTS HAVE INTERVENED INCREASINGLY IN PENAL PRACTICES, DENYING HABEAS CORPUS RELIEF TO STATE PRISONERS AND, MORE RECENTLY (1977), DENYING PRISONERS THE RIGHT TO UNIONIZE. ALTHOUGH PRISONERS' EFFORTS TO UNIONIZE DID NOT BEGIN UNTIL THE EARLY 1970'S, THEY ARE VIEWED AS A REFLECTION OF MOUNTING PRISONER MILITANCY AND ACTIVISM AND ALSO AS A CAUSE OF GUARDS' MOVE TO UNIONIZE. HOWEVER, IT COULD BE ARGUED THAT INMATE UNION ACTIVITY FOLLOWED THE EXAMPLE OF GUARD UNIONIZATION, SINCE THE FIRST GUARD UNION WAS APPARENTLY FOUNDED IN NEW YORK CITY DURING THE LATE 1950'S. THE NEW YORK CORRECTION OFFICERS' BENEVOLENT ASSOCIATION BECAME THE FIRST CORRECTIONAL EMPLOYEE UNION TO ENGAGE IN FORMAL COLLECTIVE BARGAINING. CONTEMPORARY UNIONIZATION IS RAPIDLY INCREASING, WITH A NATIONWIDE SURVEY INDICATING THAT APPROXIMATELY HALF OF THE STATE CORRECTIONAL AGENCIES OPERATE UNDER COLLECTIVE BARGAINING AGREEMENTS WITH CORRECTIONAL EMPLOYEES. THE ROLE AND IMPACT OF CORRECTIONAL UNIONS REMAIN CONTROVERSIAL, HOWEVER, AND THE CONSTITUTIONALITY OF GUARDS' UNIONS SHOULD NOT BE CONSIDERED TO BE DIFFERENT FROM THAT OF PRISONERS' UNIONS. TO RECOGNIZE ONE AND NOT THE OTHER RISKS PHYSICAL CONFLICT BETWEEN GUARDS AND PRISONERS. JUDICIAL CASE REFERENCES ARE FOOTNOTED.