Prison Legal News v. Columbia County
942 F. Supp. 2d 1068
D. Or.2013Background
- PLN sues Columbia County, CCSO, and Sheriff for First and Fourteenth Amendment violations over jail inmate mail policies.
- Policies at issue include postcard-only personal mail, prohibition on magazines, and lack of adequate notice and appeal procedures.
- Court previously enjoined postcard-only mail; record shows staff routinely rejected magazines and failed to provide notice or opportunity to appeal.
- Trial focused on liability and equitable relief; a separate damages phase may follow; the court bifurcated trials.
- PLN showed that defendants had written policies or customs restricting mail in ways that harmed PLN and inmates' rights; defendants admit some constitutional flaws.
- Court evaluates whether postcard-only policy, magazine ban, and notice/appeal deficiencies violated the First and Fourteenth Amendments and whether injunctions or declaratory relief are appropriate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did postcard-only policy violate First Amendment? | PLN and inmates’ rights were restricted by a policy not rationally related to penological objectives. | Postcard-only policy rationally related to security and efficiency; neutral in content; other protections exist. | Policy not rationally related to legitimate penological goals; violated First Amendment. |
| Did magazine ban constitute an actionable First Amendment policy or custom? | Defendants had a magazine prohibition policy/custom despite IMPs permitting magazines; liability under Monell. | There was no formal policy; staff followed manuals that banned magazines; no Monell violation. | Defendants had a policy or custom prohibiting magazines; liability under §1983 established; rights violated. |
| Were notice and appeal procedures for mail censorship adequate under the Fourteenth Amendment? | Defendants failed to notify senders and inmates or provide a meaningful appeal process for censored mail. | Subsequent IMPs created notice and appeal procedures; current standards meet due process. | Prior notice and appeal deficiencies violated due process; but declaratory and injunctive relief analyzed separately. |
Key Cases Cited
- Turner v. Safley, 482 U.S. 78 (1987) (four-factor test for prison regulations affecting rights)
- Prison Legal News v. Lehman, 397 F.3d 692 (9th Cir. 2005) (First Amendment rights to communicate with prisoners; Turner tailoring)
- Monell v. Dept. of Soc. Servs., 436 U.S. 658 (1978) (municipal liability for policy or custom)
- eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388 (2006) (permanent injunction standard and equity considerations)
- Procunier v. Martinez, 416 U.S. 396 (1974) (minimum due process protections for incoming mail in prisons)
- Beard v. Banks, 548 U.S. 521 (2006) (Turner related analysis; not a blanket standard)
- Covell v. Arpaio, 662 F. Supp. 2d 1146 (D. Ariz. 2009) (postcard-only policies; common-sense connection to security)
- Morrison v. Hall, 261 F.3d 896 (9th Cir. 2001) (limits on mail policies; evidence required for rational relation)