Beginning in the 1960's, Federal courts began to discard the traditional "hands-off" doctrine and to examine critically the conditions of prison life. In 1968, in Lee v. Washington, the U.S. Supreme Court declared mandatory racial segregation in correctional facilities unconstitutional; however, a concurring opinion did suggest that in certain limited circumstances, racial segregation might be permitted if necessary to maintain institutional security. Thus, although the Court voided official policies that mandated racial segregation in correctional facilities, it left the door open for the use of racial segregation in circumstances in which correctional administrators could show that institutional security required it. The Supreme Court also neglected to address whether prison officials had an affirmative duty to integrate rather than simply being prohibited from enforcing racial segregation. A related complaint by inmates is that racial segregation is occurring still but that it is the result of habit or official acquiescence to inmate demands. This sort of "voluntary" racial segregation creates a dilemma for corrections officials. Cases involving the "voluntary" racial segregation of inmates are few. Overall, court cases suggest the following policies: no mandatory racial segregation and a good-faith effort by corrections officials to integrate their facilities and not give in to the demands of racist inmates or to fear of a violent inmate response. 34 references