Hines v. Sheriff of White County, Indiana, 4:20-cv-00043

Plaintiff Justin Hines filed suit challenging White County Jail policies that prohibited inmates from receiving newspapers and books by mail and from wearing religious jewelry, asserting First Amendment and RLUIPA/Indiana RFRA claims.
Hines sought declaratory and injunctive relief, damages, and attorney fees; claims regarding religious jewelry and Hines’s individual damages were bifurcated from class claims.
Separate but similar suits by Bearden and Tran were consolidated; the Court certified a Rule 23(b)(2) class of all current and future White County Jail inmates.
The parties reached a settlement in principle that: (a) allows inmates one paid newspaper subscription and a procedure to request a second; (b) permits books sent directly from publishers (with limited inspection/confiscation and a three-book possession limit excluding religious texts); and (c) requires updates to the Jail Rules and dissemination to inmates and class counsel.
At a fairness hearing the magistrate received no objections from class members, reviewed compliance with Rule 23(e) and PLRA considerations, and recommended approval of the settlement and awarding class counsel $10,000 in attorneys’ fees.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the class settlement is fair, reasonable, and adequate under Rule 23(e)	Settlement provides most of the requested relief (access to books/newspapers) and avoids protracted litigation	Settlement is appropriate to resolve disputes and implement new policies without further litigation	Approved: settlement found fair, reasonable, and adequate under Synfuel factors
Adequacy of class notice and opportunity to object	Plaintiffs provided court-approved notice and opportunity to comment/appear	Sheriff implemented notice procedure; no objections were received	Held adequate under Rule 23(e); no class objections were filed
Compliance with the Prison Litigation Reform Act (PLRA) for prospective relief	Parties characterized agreement as a private settlement agreement not subject to PLRA limits on prospective relief	Sheriff argued the settlement is a private agreement and thus outside PLRA §3626(a)(1)(A) constraints	Held: Agreement is a private settlement agreement and complies with PLRA provisions cited
Reasonableness of attorneys’ fees requested ($10,000)	Counsel claimed lodestar subject to PLRA capped rate, sought compromise payment of $10,000	Defendant agreed to proposed fee allocation in settlement	Held reasonable: magistrate recommended awarding $10,000 (below PLRA-calculated max)

Isby v. Bayh, 75 F.3d 1191 (7th Cir. 1996) (federal courts favor settlement of class actions and courts must scrutinize fairness)
Williams v. Rohm & Haas Pension Plan, 658 F.3d 629 (7th Cir. 2011) (Rule 23(e) fairness review requirement)
Synfuel Techs., Inc. v. DHL Express (USA), Inc., 463 F.3d 646 (7th Cir. 2006) (lists five factors for evaluating class settlements; first factor is most important)
Willis v. Caterpillar, Inc., 199 F.3d 902 (7th Cir. 1999) (procedural rule on objections to magistrate recommendations)
Hunger v. Leininger, 15 F.3d 664 (7th Cir. 1994) (procedural rule on objections to magistrate recommendations)
The Provident Bank v. Manor Steel Corp., 882 F.2d 258 (7th Cir. 1989) (procedural consequences of failing to object to magistrate recommendations)
Lebovitz v. Miller, 856 F.2d 902 (7th Cir. 1988) (procedural consequences of failing to timely object to magistrate recommendations)