In the Matter of John Doe v. Thomas A. Coughlin, III, as Commissioner of the New York State Department of…

Summary

The New York Court of Appeals affirmed the Appellate Division, holding that the denial of conjugal visits to an inmate with AIDS did not violate any constitutional right to marital privacy, due process, equal protection, or the Rehabilitation Act. The Court reasoned that prisoners have no inherent right to conjugal visitation and that the regulation was rationally related to legitimate penological interests. A dissent argued that the denial infringed a fundamental marital privacy right and should be subject to heightened scrutiny.