[1] directly advances [2] a substantial governmental interest and [3] that the measure is drawn to achieve that interest” (citing Cent. Hudson Gas & Elec. Corp. v. Pub. Serv. Comm’n of N.Y., 447 U.S. 557, 566, 100 S.Ct. 2343, 65 L.Ed.2d 341 (1980))). I therefore believe that Casey applied something akin to intermediate First Amendment scrutiny. Even if Casey applied something less than intermediate scrutiny, Zauderer v. Office of Disciplinary Counsel of the Supreme Court of Ohio, 471 U.S. 626, 105 S.Ct. 2265, 85 L.Ed.2d 652 (1985), confirms that intermediate scrutiny applies here. In that case, the Court applied a “reasonable relation” standard of First Amendment review, similar — in wording, though not necessarily in form — to the one applied in Casey. Id. at 651, 105 S.Ct. at 2282 (<HOLDING>). Zauderer explained that the reasonableness
holding that when a prison regulation impinges on inmates constitutional rights the regulation is valid if it is reasonably related to legitimate penological interests holding that validity of regulations will be sustained as long as  reasonably related to the purposes of the enabling legislation  holding that although the first amendment was implicated the regulation compelling disclosure of certain information in advertisements was constitutional as long as it was reasonably related to the states interest holding the states smv statute as applied to old order amish defendants unconstitutional because the states interest in public safety was not sufficiently compelling to override the right to free exercise protected by the first amendment of the united states constitution holding that prison administration may infringe upon prisoners first amendment rights as long as the infringement is reasonably related to legitimate penological interest