The U.S. Supreme Court case William Overton, Director, Michigan Department of Corrections, et al. v. Michelle Bazzetta et al., 2002 revolved around the constitutionality of certain regulations imposed by the Michigan Department of Corrections (MDOC) on prison visitations. The MDOC had implemented rules that limited visits from children and former inmates unless they were legal family members and also restricted visits for prisoners with two or more substance abuse violations. A group of inmates and their potential visitors challenged these restrictions as a violation of their First Amendment rights to association and Fourteenth Amendment due process rights. In a unanimous decision led by Justice Kennedy, the court upheld most parts of MDOC's regulations stating that while imprisonment does not automatically strip away constitutional protections, some limitations are necessary for security purposes in prisons which is government’s compelling interest here. However it asked lower courts to review whether complete ban on visitation after two drug violations was justified or not because this could potentially be seen as cruel punishment if alternative means for achieving same objective existed.

In the dissenting opinion for Overton v. Bazzetta, Justice Thomas argued that the majority's decision to uphold restrictions on prison visitation rights was a misinterpretation of precedent and an overreach of judicial power. He contended that there is no constitutional right to unfettered visitation in prisons and thus, any regulation should be left entirely up to prison administrators unless it can be proven as punishment inflicted cruelly or unusually. In his view, the regulations were not punitive but rather aimed at maintaining order within prisons and deterring drug smuggling - both legitimate goals for correctional facilities. Therefore, he believed they did not violate inmates' Eighth Amendment rights against cruel and unusual punishment nor their Fourteenth Amendment due process rights.