Otis L. Smith v. Paul Delo Debbie Reed

MORRIS SHEPPARD ARNOLD,

dissenting.

I respectfully dissent. Procunier v. Martinez, 416 U.S. 396, 94 S.Ct. 1800, 40 L.Ed.2d 224 (1974), as limited by Thornburgh v. Abbott, 490 U.S. 401, 109 S.Ct. 1874, 104 L.Ed.2d 459 (1989), controls this case and requires us to hold that the Missouri prison mail regulations are unconstitutional. While Martinez does not impose a “least restrictive means” test on prison regulation of outgoing mail, it does require that a regulation’s “limitation of [inmates’] First Amendment freedoms must be no greater than is necessary or essential to the protection of the particular governmental interest involved.” Martinez, 416 U.S. at 413, 94 S.Ct. at 1811. In other words, it requires that the challenged regulation be “generally necessary” to a legitimate government interest. Thornburgh v. Abbott, 490 U.S. at 411, 109 S.Ct. at 1880 (citing Martinez, 416 U.S. at 414, 94 S.Ct. at 1811).

The defendants here maintain that the regulations were imposed in the interest of prison security. The Abbott Court, however, observed that outgoing prisoner mail does “not pose, by its very nature, a serious threat to prison order and security.” 490 U.S. at 411, 109 S.Ct. at 1880. Defendants have presented nothing to indicate that the situation within their prison system is materially different from that assessed in Abbott. They make only general assertions that prisoners will use any means possible to breach prison security, a proposition that we may admit without necessarily approving the means to which they have resorted to ensure prison security.

The Missouri regulation is similar to those that have been upheld when used to screen incoming mail, which is considered a much greater threat to prison security. See, e.g., Turner v. Safley, 482 U.S. 78, 107 S.Ct. 2254, 96 L.Ed.2d 64 (1987) (upholding prison regulation disallowing mail between inmates except that between immediate family members who are inmates at different institutions); Abbott, 490 U.S. 401, 109 S.Ct. 1874 (upholding prison regulation allowing warden to reject any publication ordered by inmate if the publication is detrimental to security, good order, or discipline, or if it might facili*833tate criminal activity). The same type of regulation considered generally necessary to screen incoming mail can hardly be considered generally necessary to screen outgoing mail because the former admittedly poses a far greater threat to prison security than does the latter. A regulation commensurate with the lesser threat to security might include mailroom verification that an addressee of sealed correspondence is a member of the staff of a legitimate media or religious organization (just as they do now with correspondence to attorneys, judges, and other privileged legal addressees). Such a regulation would eliminate the inevitable chilling effect that the current restriction has on inmates’ exercise of their First Amendment rights.

At bottom, my disagreement with the court has to do with my inability to perceive any juridical distinction between the safeguards required to protect the First Amendment rights asserted here and those required to safeguard the rights secured by the Sixth Amendment.

I would therefore reverse.