Vance

We are asked to decide constitutional challenges to the administration of inmate trust accounts by state prison authorities.

I

To avoid the attendant problems that one might imagine would arise from inmates keeping currency in their cells, Nevada Department of Prisons (“NDOP”) inmates are required, by statute, to keep their money in a personal property trust fund run by the State of Nevada. Nev. Rev.Stat. 16 § 209.241(1) (1993). 1 Any money earned by an inmate during incarceration is credited to such fund, and any money sent to the inmate by outside sources such as friends and relatives is to be deposited in such fund.

Each inmate has a personal property account and a savings account. An inmate’s personal property account is used for his personal needs. Twenty percent of an inmate’s earnings from prison work are deposited into such account. The remaining eighty percent of an inmate’s wages is automatically deposited in his savings account for use following incarceration. Once an inmate’s savings account reaches a balance of $200 any amount in excess may be transferred to his personal account.

By statute, “interest and income earned on the money in the [overall] fund,…