Shawn Stauffer v. Marna Gearhart
2014 U.S. App. LEXIS 1492
| 5th Cir. | 2014Background
- Shawn Stauffer, a convicted attempted aggravated sexual assaulter of a child, was enrolled in Texas Department of Criminal Justice (TDCJ) Sex Offender Treatment Program (SOTP) for the final 18 months of his incarceration.
- SOTP restricted participant mail under SOTP 02.06: generally no publications except newspapers and religious material; sexually suggestive/explicit material rejected; no appeals to Director’s Review Committee on these restrictions.
- Goree Unit mailroom confiscated several automotive magazines Stauffer ordered; Stauffer said the magazines were vocationally relevant to his automotive trade.
- Stauffer sued under 42 U.S.C. § 1983 claiming violations of the First Amendment, Fourteenth Amendment (due process and equal protection), and later alleged retaliation; he sought injunctive relief and monetary damages against multiple TDCJ employees.
- District court granted summary judgment for defendants on injunctive and damages claims; TDCJ later revised SOTP 02.06 to require individualized review and to align with Board Policy 03.91. The Fifth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether SOTP 02.06 violated First Amendment right to receive publications | Stauffer: confiscation of car magazines infringed his right to receive vocationally relevant publications | TDCJ: regulation reasonably related to legitimate penological interest in sex-offender rehabilitation and preventing distractions | Court: regulation was not shown to be irrational; First Amendment claim fails (and qualified immunity protects officers) |
| Whether SOTP 02.06 violated Equal Protection by targeting SOTP participants/sex-offenders | Stauffer: rule impermissibly singled out sex-offenders without rational justification | TDCJ: classification is not suspect; rationally related to rehabilitation goals | Court: rational-basis review satisfied; Equal Protection claim fails |
| Whether TDCJ denial procedure violated Due Process | Stauffer: mail denials lacked meaningful review and appeal | TDCJ: grievance process provided review; written responses were available | Court: grievance process sufficed; no due process violation stated |
| Whether relief for injunction or damages was available | Stauffer: sought injunction and monetary relief (nominal, compensatory, punitive) | TDCJ: policy was later revised (mooting injunctive/declaratory relief); §1997e(e) bars compensatory damages without physical injury; qualified immunity and Eleventh Amendment bar damages against state/official-capacity defendants | Court: Injunctive/declaratory claims moot due to revised policy; monetary damages barred or unavailable — compensatory barred by §1997e(e), official-capacity claims barred, individual defendants entitled to qualified immunity for damages |
Key Cases Cited
- Turner v. Safley, 482 U.S. 78 (Sup. Ct.) (prison regulations that impinge on constitutional rights are valid if reasonably related to legitimate penological interests)
- Thornburgh v. Abbott, 490 U.S. 401 (Sup. Ct.) (deference to prison administrators and reasonableness standard for prison regulations)
- Beard v. Banks, 548 U.S. 521 (Sup. Ct.) (courts must defer to prison officials’ professional judgments on institutional operations)
- Ashcroft v. al-Kidd, 563 U.S. 731 (Sup. Ct.) (qualified immunity requires that the right be clearly established)
- Hudson v. Palmer, 468 U.S. 517 (Sup. Ct.) (intentional deprivation of property by state officials does not give rise to § 1983 claim when adequate state post-deprivation remedies exist)
- McKune v. Lile, 536 U.S. 24 (Sup. Ct.) (recognition of strong government interest in sex-offender rehabilitation)
- Prison Legal News v. Livingston, 683 F.3d 201 (5th Cir.) (application of Turner factors and deference to prison mail censorship decisions)
- Mann v. Smith, 796 F.2d 79 (5th Cir.) (underinclusive prison restriction struck down where alternatives undermined rationale)
- Green v. Ferrell, 801 F.2d 765 (5th Cir.) (similar underinclusive restriction invalidated)
- Celotex Corp. v. Catrett, 477 U.S. 317 (Sup. Ct.) (summary judgment standards)
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (Sup. Ct.) (state and state officials sued in official capacity are not "persons" under § 1983)
- Geiger v. Jowers, 404 F.3d 371 (5th Cir.) (no federal due process interest in having prison grievances investigated to satisfaction)
- Mayfield v. Texas Dep’t of Criminal Justice, 529 F.3d 599 (5th Cir.) (§1997e(e) bars recovery of compensatory damages absent physical injury)