From Dothard v. Rawlinson (1977):

MR. JUSTICE STEWART delivered the opinion of the Court.

Appellee Dianne Rawlinson sought employment with the Alabama Board of Corrections as a prison guard, called in Alabama a "correctional counselor." ... A correctional counselor's primary duty within these institutions is to maintain security and control of the inmates by continually supervising and observing their activities. [fn 8]

[fn 8] The official job description for a correctional counselor position emphasizes counseling as well as security duties; the District Court found: "[C]orrectional counselors are persons who are commonly referred to as prison guards. Their duties primarily involve security rather than counseling."