The Michigan Department of Corrections (MDOC) barred males from working in certain positions at its female prisons. MDOC designated approximately 250 positions in housing units at female prisons as “female only.” The duties of COs and RUOs in the housing units include patrolling the sleeping, shower, and bathroom areas; attending to the basic needs of women prisoners (including the provision of sanitary supplies); monitoring activity in the living quarters; enforcing housing rules and procedures, and ensuring that proper standards of care and hygiene are maintained.

The court ruled that this policy did not constitute illegal discrimination on the basis of gender. It concluded that because of the endemic problem of sexual abuse in female prisons, MDOC’s plan is reasonably necessary to the normal operation of its female prisons. Discuss what aspect of the justice theory this case illustrates.