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Jones v. Brown - 461 F.3d 353 (3d Cir. 2006)

Rule:

Federal courts must take cognizance of the valid constitutional claims of prison inmates. However, prison administration is an inordinately difficult undertaking, aspects of which are peculiarly within the province of the legislative and executive branches of government. In light of these principles, a prison regulation that impinges on the constitutional rights of prisoners is nonetheless valid, so long as the regulation is reasonably related to legitimate penological interests.

Facts:

In response to the terrorist attack of September 11, 2001, and the receipt of letters contaminated with anthrax, N.J. Admin. Code § 10A:18-3.4 suspended the prior regulatory requirement that legal mail be opened in the inmates' presence to protect the health, safety, and welfare of the people and to aid in the prevention of loss to and destruction of property. In case one, the district court granted the inmates injunctive relief but denied them monetary damages. In case two, the district court granted the officials summary judgment and held that policy was a valid exercise of administrative discretion. Plaintiff inmates appealed the judgments of the district court.

Issue:

Does prior opening of letters outside the presence of inmates violate their First Amendment rights?

Answer:

Yes.

Conclusion:

The court found that the inmates established that the officials infringed upon their First Amendment rights. More than three years after the terrorist attack, there was no reasonable connection between the legal mail policy and the officials' asserted interest because of the de minimis risk of an anthrax attack on New Jersey prisons. However, the inmates were not entitled to monetary damages because the officials reasonably believed they were acting in the interest of inmate and staff health and safety and they were entitled to qualified immunity.

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