Starling v. Maury County Jail
1:13-cv-00157
M.D. Tenn.Mar 9, 2015Background
- Starling, an Odinist inmate, was housed at Maury County Jail from July 28, 2013 to April 28, 2014.
- Starling sought a religious text, The Temple of Wotan, which the jail Chaplain would approve before delivery.
- The book was brought by Starling’s father on August 27, 2013, but access required Chaplain approval.
- Jail procedures prohibit literature that promotes racial/ethnic supremacy or that promotes hatred or jeopardizes jail security.
- The Chaplain found white-supremacy references in The Temple of Wotan and Wagonschutz denied the request to provide it.
- Starling also sought dietary and material accommodations (vegan diet, rune cloth), which were denied for lack of supporting Odinist requirements and presence of a swastika on the cloth.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the jail policy restricting racist religious literature violates the First Amendment | Starling contends policy restricts Odinist expression. | Defendants assert policy reasonably relates to institutional safety and order. | Policy reasonably related to penological interests; no constitutional violation found. |
| Whether Wagonschutz is entitled to qualified immunity | Starling claims a right to receive the literature. | Wagonschutz acted within a clearly established policy; rights not violated. | Wagonschutz entitled to qualified immunity; no violation established. |
| Whether injunctive relief claims are moot | Injunctive relief should be available to restore access. | Plaintiff is no longer incarcerated; relief moot. | Injunctive relief claims moot due to transfer to another facility. |
Key Cases Cited
- Cruz v. Beto, 405 U.S. 319 (U.S. 1972) (prisoners' religious exercise rights while balancing safety)
- Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (governmental interests in maintaining institutional order)
- Turner v. Safley, 482 U.S. 78 (U.S. 1987) (reasonableness standard for prison regulations related to rights)
- Walker v. Mintzes, 771 F.2d 920 (6th Cir. 1985) (reasonableness of prison policies in Turner framework)
- Kensu v. Haigh, 87 F.3d 172 (6th Cir. 1996) (mootness and injunctive relief considerations in prison cases)
- Duchon v. Cajon Co., 791 F.2d 43 (9th Cir. 1986) (summary judgment standard and factual view)
- Lindell v. Casperson, 360 F. Supp. 2d 932 (W.D. Wis. 2005) (analysis of prison literature restrictions)