1999) (unpublished) (citing Turner, 482 U.S. at 87, 107 S.Ct. 2254). For example, the room and board fee may help defray taxpayer liability for the considerable expense of incarcerating criminal offenders. Additionally, the room and board fee may engender fiscal responsibility in VBCJ’s inmates. And finally, the room and board fee may contribute to the overall well-being of the local inmate population as the collected fees are used for general jail purposes. Va. Code § 53.1-131.3 (2003). Therefore, even assuming arguendo that the VBCJ room and board fee is of constitutional significance, the fee is reasonably related to the promotion of legitimate penological interests. III. Conclusion Therefore, for the reasons stat .), cert. denied, 506 U.S. 905, 113 S.Ct. 299, 121 L.Ed.2d 222 (1992) (<HOLDING>). 4 . Estelle v. Gamble, 429 U.S. 97, 104-05,
holding that life without parole sentences for nonhomicide offenses violates the eighth amendment holding that denial of outofcell exercise for an extended period violates the eighth amendment holding that the execution of mentally retarded criminals violates the eighth amendment holding that execution of juveniles violates the eighth and fourteenth amendments holding that malicious or sadistic use of force with intent to harm violates the eighth amendment