Minton v. Childers, 113 F. Supp. 3d 796

Plaintiff William Minton, an inmate at Eastern Correctional Institution (ECI), sued under 42 U.S.C. § 1983 after prison staff refused to deliver three used/"old stock" books he ordered from a bookstore, offering destruction or return at his expense.
Staff (Childers) placed the books on a 30-day hold pending Minton’s filing of an administrative remedy procedure (ARP); defendants say the books remain in ECI custody pending the administrative outcome.
Defendants rely on an ECI directive (consistent with Division of Correction policy) prohibiting incoming used books from non-publishers (e.g., Amazon, eBay) for security reasons; new books must be sent directly from publishers and are inspected at a central warehouse.
Minton alleges the ban violates his due process and First Amendment rights and points to a prior favorable case on a similar issue; he also contends he pursued ARP/IGO remedies during this litigation.
Defendants moved to dismiss or for summary judgment (construed as summary judgment), arguing Minton failed to exhaust administrative remedies under the PLRA and, alternatively, that the policy is reasonably related to legitimate penological interests.
The court found no genuine dispute of material fact, granted defendants’ summary judgment, denied Minton’s summary judgment and injunctive relief, entered judgment for defendants, and closed the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion of administrative remedies under PLRA	Minton says he filed ARPs and pursued remedies through the IGO during the case	Defendants say Minton did not complete the required ARP/IGO appeals before filing suit	Court held Minton failed to exhaust available administrative remedies; dismissal required absent exhaustion
Constitutionality of ECI ban on incoming used books	Minton contends a blanket ban on published material (esp. novels) is not reasonably related to security and violates due process/First Amendment	Defendants argue the ban is neutral, aimed at security (contraband risk in used book bindings), and allows new books from publishers	Court held the ban is constitutional under Turner; reasonably related to legitimate penological interests
Availability exception to exhaustion (prevented access)	Minton implies ongoing pursuit of remedies and past litigation suggests confusion	Defendants maintain remedies were available and not exhausted	Court found no basis to excuse exhaustion; remedies were available and procedural rules not followed
Request for injunctive relief and damages	Minton seeks injunctive relief and nominal/punitive damages for deprivation of books	Defendants seek judgment and dismissal	Court denied injunctive relief and plaintiff’s summary judgment; entered judgment for defendants

Turner v. Safley, 482 U.S. 78 (prison regulation valid if reasonably related to legitimate penological interests)
Thornburgh v. Abbott, 490 U.S. 401 (Turner framework applies to incoming publications; neutrality requirement)
Porter v. Nussle, 534 U.S. 516 (PLRA exhaustion applies to "prison conditions" claims)
Woodford v. Ngo, 548 U.S. 81 (exhaustion requires compliance with procedural rules)
Booth v. Churner, 532 U.S. 731 (prisoner must seek full administrative review to satisfy PLRA)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standards)
Moore v. Bennette, 517 F.3d 717 (availability and exhaustion in Fourth Circuit)
Dole v. Chandler, 438 F.3d 804 (exhaustion occurs even if prison officials do not respond)