Winston Holloway Jeff Arbaugh Larry Jones and Terry Proctor v. Dennis Pigman, Chaplain Dewie W. Williams, Chaplain Arthur Lockhart, Director, A.D.C. Randy Morgan, Asst. Director Larry Norris, Warden Marvin Evans, Asst. Warden Robert Perry, Major, Tucker Unit Board of Correction, All in Their Individual and Official Capacities

Citations: 884 F.2d 365; 1989 U.S. App. LEXIS 13084Docket: 88-1685

Court: Court of Appeals for the Eighth Circuit; August 31, 1989; Federal Appellate Court

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Winston Holloway, Jeff Arbaugh, Larry Jones, and Terry Proctor, inmates in the Maximum Security Unit of the Arkansas Department of Corrections, filed a civil rights lawsuit under 42 U.S.C. Sec. 1983. They alleged violations of their religious freedom, speech, association rights, and due process and equal protection by prison chaplains, officials, and the Board of Corrections. The district court granted summary judgment for the defendants on claims regarding Holloway's access to religious items and mail interference, and it dismissed the claim about misuse of inmate welfare funds for failure to state a claim.

On appeal, the plaintiffs contended that the district court made errors by granting summary judgment, arguing that genuine material facts existed regarding Holloway's access to Native American religious items and procedural deficiencies in the prison mail system that violated their due process rights. They also claimed the district court wrongly dismissed their welfare fund misuse allegation.

In reviewing the summary judgment, it is essential to identify any disputed material facts that could affect the case's outcome. The presence of a genuine issue of fact must align with a viable legal theory under the nonmoving party's perspective. Holloway claimed he was denied the ability to practice his religion, asserting that Warden Norris had restricted his access to certain religious items. However, Warden Norris countered this by stating he had not hindered Holloway's religious practices and claimed not to possess the items in question. Holloway attempted to refute Norris by providing grievances and an Inmate Personal Property Record indicating that the items were stored in the warden's office.

The court applied a reasonableness standard, determining that prison regulations could infringe on a prisoner’s rights if they were reasonably related to legitimate penological interests. Holloway failed to detail the requirements of his religious practice or demonstrate that he was entirely deprived of practicing his religion. The court concluded that any dispute regarding the existence of the items was not material, leading to the affirmation of the district court's summary judgment.

Plaintiffs allege that defendants denied them access to mail at MSU without prior notice or an opportunity to contest the denial, specifically noting delays and confiscations of first-class mail addressed to Holloway from family and friends. The complaint claims that plaintiffs received no notifications regarding mail rejection or censorship. In contrast, Warden Norris stated in an affidavit that inmates are notified when mail that violates departmental policy is returned to the sender, but no process exists for inmates to contest these decisions. Inmates on punitive status cannot receive general correspondence until they revert to a non-punitive status and are not informed of incoming mail during this period. The court previously upheld the constitutionality of temporary mail restrictions as a disciplinary measure. Holloway's claims about mail delays during punitive status were deemed a random misapplication of reasonable regulations, not sufficient to challenge the summary judgment. The court applied the reasonableness standard outlined by the Supreme Court in Turner, concluding that plaintiffs failed to provide evidence that mail distinctions were made for reasons other than security. Additionally, plaintiffs contested the use of the inmate welfare fund, claiming deprivation of property rights without due process. The district court dismissed this claim, determining it was not cognizable under 42 U.S.C. Sec. 1983, a conclusion the current court affirms.