In the last three decades a number of cases in the United Kingdom (UK) and American courts have challenged penal policies and practices in relation to prisoners' access to fertility services. Debates around whether prisoners should have access to services for assisted reproductive technologies (ART) go hand in hand with ongoing controversies about sexual behaviour in prisons, family contact and 'conjugal' or private visits in which couples are afforded sufficient privacy to engage in sexual activity. In Mellor, the Court of Appeal upheld a judgement dismissing an application for access to insemination facilities from Gavin Mellor, a prisoner serving a life sentence. A challenge was brought jointly by Kirk and Lorraine Dickson, one a serving prisoner and the other an ex-prisoner, who had married in a prison ceremony in 2001. The Dickson case differed from Mellor in that the application and the subsequent legal decisions explicitly addressed the wife's rights as well as the prisoner's.