A Wolf in Sheep's Clothing: Wolf versus Ashcroft and the Constitutionality of using the MPAA Ratings to Censor Films in Prison

Part I of this article looks at the history of the federal courts' jurisprudence in deciding prisoner's rights cases, culminating in the current test adopted in on Turner v. Safley. Part II considers the purposes behind the Zimmer Amendment and looks at the district and appellate court rulings in the Pennsylvania prisoners' case, Wolf v. Ashcroft. Part III looks at the history of the MPAA ratings and cases dealing with their legal enforceability. Finally, Part IV applies Turner's test to the Zimmer Amendment and the Pennsylvania policy prohibiting R, X, and NC-17 movies from being shown in prison, ultimately concluding that the Zimmer Amendment is unconstitutional because it impermissibly relies on the MPAA ratings.