Prison Legal News v. Lehman - 397 F.3d 692 (9th Cir. 2005)

Rule:

The United States Supreme Court has laid out a four-factor test to determine whether a prison regulation is reasonably related to legitimate penological interests: (1) whether the regulation is rationally related to a legitimate and neutral governmental objective, (2) whether there are alternative avenues that remain open to the inmates to exercise the right, (3) the impact that accommodating the asserted right will have on other guards and prisoners, and on the allocation of prison resources; and (4) whether the existence of easy and obvious alternatives indicates that the regulation is an exaggerated response by prison officials. The first factor of these factors constitutes sine qua non. Therefore, if a regulation is not rationally related to a legitimate and neutral governmental objective, a court need not reach the remaining three factors. 

Facts:

Prison Legal News is a Washington nonprofit corporation that publishes and distributes publications regarding legal issues of interest to inmates, such as prisoners' rights. It publishes a monthly subscription magazine, which has 3,000 subscribers across the United States, including 120 who are inmates in Washington's state correctional facilities. Its editor, Paul Wright, is an inmate in a Washington state correctional facility. The Washington Department of Corrections ("DOC") appealed from the grant of summary judgment and permanent injunctive relief on Prison Legal News and Rollin A. Wright's (collectively "PLN") claim that the DOC prohibition against the receipt by inmates of non-subscription bulk mail and catalogs violates the First and Fourteenth Amendments. The thirteen individual defendants ("prison officials") appealed from the denial of their motion for summary judgment based on their defense of qualified immunity from damages as a result of restricting inmates from receiving third-party legal materials. PLN has filed a cross-appeal from the order granting summary judgment to the thirteen individuals based on their defense of qualified immunity regarding PLN's claim that the prison officials violated its constitutional rights.

Issue:

Was DOC's ban on non-subscription bulk mail and catalogs constitutional?

Answer:

No

Conclusion:

The court held that the district court properly granted summary judgment to PLN regarding the ban on non-subscription bulk mail and catalogs because the ban was not rationally related to a legitimate penological objective. The court agreed that there was no rational relation between the mail regulation and the penological objective of reducing the amount of mail that may contain contraband. Further, given the regulation limiting the quantity of possessions that prisoners may have in their cells, the theory that the mail regulation reduced fire hazards or increased the efficiency of cell searches was rejected. The court further concluded that the district court properly denied the prison officials' motion for summary judgment based on qualified immunity regarding plaintiffs' third-party legal materials claim, because it had to accept as true plaintiffs' allegations that the prison officials applied the policy in a way that discriminated against PLN on the basis of the content of the legal materials (PLN suggested that the real motive of the prison officials was to suppress materials that embarrassed the DOC and educated inmates on how to file their claims).