While you might think of masturbation as a sort of last refuge for the incarcerated—a truly inalienable freedom, given the happy proximity of the sex organs—that is not the case. In fact, a number of state prisons regard jerking off as a rule infraction. American University law professor Brenda Smith, who conducted a 50-state survey of prison masturbation policies in 2006, says restrictions are “well-entrenched” in the correctional environment. In North Carolina, for example, it is a violation to “touch the sexual or other intimate parts of oneself or another person for the purpose of sexual gratification.” Violations can lead to disciplinary segregation or the loss of “good time” credits. Tennessee forbids “[a]ny behavior intended for the sexual gratification of the subject.” Ohio prohibits “[s]eductive or obscene acts, including indecent exposure or masturbation.” Kentucky regards inmate masturbation as “[i]nappropriate sexual behavior.” In California, where some 170,000 men and women live behind bars, masturbation is permissible provided it is stopped immediately if noticed by staff, blue balls be damned. If the masturbator perseveres, even if concealed by bed sheets, he can be cited for “Intentionally Sustained Masturbation without Exposure.” These policies are part of a long correctional tradition to forbid all forms of sexual activity.