Thomas Matherly v. J.F. Andrews
859 F.3d 264
4th Cir.2017Background
- Thomas Matherly, civilly committed under the Adam Walsh Act (18 U.S.C. § 4248) and housed in the Maryland Unit at FCI Butner, sued BOP officials in their official capacities alleging unconstitutional conditions of confinement and wage violations.
- Maryland Unit houses only civil detainees but shares facilities and daily contact with prisoners (mess hall, staff offices, food carts, haircut services); detainees wear prisoner uniforms, have similar commissary/TV restrictions, and are double-bunked.
- Matherly alleged strip searches and mass shakedowns were used punitively, mail (incoming/outgoing) was broadly screened, and educational/vocational opportunities were inferior to prisoners’; he also claimed FLSA minimum-wage entitlement for BOP work.
- District court dismissed some claims (BOP policy parity, commingling/speculative harm, FLSA) and allowed strip-search/shakedown, mail, and educational/vocational claims to proceed; summary judgment later granted for defendants on all surviving claims.
- On appeal the Fourth Circuit reviewed standards applicable to civil detainees, assessed whether challenged practices were punitive or reasonably related to nonpunitive objectives (security, treatment, public protection), and affirmed the district court in full.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| BOP policies (uniforms, commissary, TV, double-bunking) — punitive? | Conditions identical/similar to prisoners create a presumption of punishment. | Conditions are incident to legitimate, nonpunitive confinement and BOP professional judgment; no punitive intent shown. | Dismissed: plaintiff must show expressed intent to punish or lack of reasonable relation to objectives; parity with prisoners not dispositive. |
| Commingling with prisoners / safety threats | Frequent contact and taunts create imminent risk of harm violating due process. | Contacts are incidental to confinement; alleged taunts are not constitutional violations; claims of possible future harm are speculative. | Dismissed for failure to plead punitive intent and for lack of standing — alleged future harm too speculative. |
| Mail screening (First Amendment) | BOP reviews all non-legal incoming/outgoing mail; procedures allegedly overbroad and not reasonably related to legitimate interests. | Screening is responsive to intercepted threats and treatment concerns; multi-level review and supervisory withholding preserve interests. | Summary judgment for defendants: modified Turner reasonableness standard for civil detainees applies; mail inspection/censorship reasonably related to security and treatment. |
| FLSA — entitlement to minimum wage for detainee work | Work performed for BOP should qualify Matherly as an "employee" under FLSA. | Harker and circuit precedent: inmate/detainee labor is rehabilitative, not an employee relationship; FLSA not applicable. | Dismissed: FLSA does not apply to civil detainees doing prison work under controlling Fourth Circuit precedent. |
| Educational/vocational opportunities — punitive? | Denial/limitation of programs compared to prisoners is inherently punitive and undermines rehabilitation. | CTP therapy is primary, safety requires population separation, limited demand and high cost justify exclusion from certain prison-offered courses. | Summary judgment for defendants: programs and limitations are reasonably related to rehabilitation, security, and resource allocation; no punitive intent shown. |
Key Cases Cited
- Youngberg v. Romeo, 457 U.S. 307 (civil detainees entitled to more considerate treatment; courts must ensure professional judgment)
- Bell v. Wolfish, 441 U.S. 520 (pretrial detainees may not be punished; two-part test for punishment)
- Martin v. Gentile, 849 F.2d 863 (4th Cir.) (apply Bell test to civil detainee conditions)
- Jones v. Blanas, 393 F.3d 918 (9th Cir.) (presumption of punitive conditions if detention conditions are similar/more restrictive than prisoners — declined here)
- Seling v. Young, 531 U.S. 250 (conditions and duration must bear reasonable relation to commitment purpose)
- Kansas v. Hendricks, 521 U.S. 346 (states’ latitude in treatment regimens for sexually dangerous persons)
- Heyer v. U.S. Bureau of Prisons, 849 F.3d 202 (4th Cir.) (BOP’s security and treatment interests for Adam Walsh detainees)
- Florence v. Bd. of Chosen Freeholders, 566 U.S. 318 (prison searches justified by security; unpredictability of searches important)
- Turner v. Safley, 482 U.S. 78 (regulation valid if reasonably related to legitimate penological interests; four-factor test)
- Thornburgh v. Abbott, 490 U.S. 401 (incoming mail treated under Turner)
- Altizer v. Deeds, 191 F.3d 540 (4th Cir.) (applying Turner/Procunier framework to prisoner mail inspections)
- Harker v. State Use Industries, 990 F.2d 131 (4th Cir.) (FLSA does not apply to inmate work programs)
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (standing requires concrete and imminent injury)
- Susan B. Anthony List v. Driehaus, 134 S. Ct. 2334 (standing third-element framework)
- Clapper v. Amnesty Int’l USA, 133 S. Ct. 1138 (imminence requirement for future injuries)