Resource: Court Challenges to Prison Behavior Modification Programs: A Case Study

Prisoners at a growing number of institutions throughout the country have been subjected to behavior modification programs designed to alter the conduct of inmates identified as disciplinary problems. In a substantial number of the programs officials impose upon unwilling prisoners conditions which radically change the traditional terms of imprisonment. The imposition of these changes raises serious constitutional questions. The purpose of this article is to analyze the conduct of a case, Armstrong v. Bensinger,' challenging the constitutionality of an inmate behavior modification program in Illinois.