The following excerpt is from First Amendment Coal., Inc. v. Ryan, No. 17-16330 (9th Cir. 2019):
First, we determined that a deferential standard of review is appropriate in this context because executions take place inside prisons, and corrections officials must have broad discretion to carry out the complex task of prison administration. See id. at 877-79. We thus analyzed whether California's regulation was "reasonably related to legitimate penological objectives, or whether it represent[ed] an exaggerated response to those concerns." Id. at 878 (quoting Turner v. Safley, 482 U.S. 78, 87 (1987)). We explained that there needed to be a "closer fit" between the regulation and any legitimate penological objectives because the California regulation at issue did not leave room for case-by-case discretion. See id. at 879. The restriction categorically banned witnesses from viewing the initial procedures of executions, regardless of whether there were any specific security concerns.
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