Terrance Flynn v. Marion Thatcher, 819 F.3d 990

Terrance Flynn, an Indiana prisoner, sued under 42 U.S.C. § 1983 claiming unequal treatment because he was denied privileges granted to participants in an inmate "Honor Program."
The Honor Program grants extra out-of-cell time, more visits, video-game access, exercise machines, and microwave access to participants who meet eligibility (age minimum recently lowered from 35 to 30, no infractions for specified periods).
Flynn alleges he met the program's behavioral criteria but was denied admission (initially for age, later because the program and waiting list were full); he seeks the same privileges without entry into the program.
The district court construed the complaint as an age-discrimination equal-protection claim and dismissed for failure to state a claim; Flynn moved for reconsideration and the motion was denied.
On appeal Flynn abandoned the age-discrimination claim and pressed a general equal-protection challenge to the disparate treatment between general-population inmates and Honor Program participants.
The Seventh Circuit affirmed, holding the differential treatment is rationally related to legitimate penological interests and therefore does not violate equal protection.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denying nonparticipants the Honor Program privileges violates Equal Protection	Flynn: denying him privileges despite allegedly meeting behavioral criteria is disparate treatment without legitimate penological basis	Prison officials: distinctions are rationally related to legitimate penological interests (rehabilitation, security, safety) and program admission process is justified	Affirmed — rational-basis review applies; program distinctions are rationally related to legitimate penological interests

City of Cleburne, Tex. v. Cleburne Living Ctr., 473 U.S. 432 (equal protection principles and rational-basis review)
Johnson v. Daley, 339 F.3d 582 (7th Cir. 2003) (prison classification rational-basis review)
May v. Sheahan, 226 F.3d 876 (7th Cir. 2000) (prisoner equal-protection standards)
Stanley v. Litscher, 213 F.3d 340 (7th Cir. 2000) (deference to prison administrators)
Ind. Petroleum Marketers & Convenience Store Ass'n v. Cook, 808 F.3d 318 (7th Cir. 2015) (presumption of rationality for classifications)
McGinnis v. Royster, 410 U.S. 263 (prison rules serving legitimate penological objectives)
Singer v. Raemisch, 593 F.3d 529 (7th Cir. 2010) (prison practices and security justifications)
Harbin-Bey v. Rutter, 420 F.3d 571 (6th Cir. 2005) (rewards for good behavior serve penological interests)
Woodson v. Attorney Gen., 990 F.2d 1344 (D.C. Cir.) (privileges as incentives for good conduct)
Robinson v. Sherrod, 631 F.3d 839 (7th Cir.) (procedural note on strikes under § 1915(g))
Hains v. Washington, 131 F.3d 1248 (7th Cir.) (§ 1915(g) strikes guidance)