The first state to implement conjugal visits was Mississippi in the Mississippi State Penitentiary (Parchman). It was enacted to convince black male prisoners to work harder in their manual labor.[35] This was done unofficially at first, but had become official policy at Parchman Penitentiary by the 1950s.[35]

In Lyons v. Gilligan (1974), the United States District Court for the Northern District of Ohio held that prisoners have no federal constitutional right to conjugal visits with their spou