Haze v. Harrison, No. 18-7340 (4th Cir. 2020)
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Plaintiff filed a pro se 42 U.S.C. 1983 action alleging that prison officials opened, copied, misdirected, and otherwise interfered with his mail to and from his lawyer. The district court granted summary judgment to defendants.
The Fourth Circuit considered the Turner factors and concluded that they weighed in favor of plaintiff, holding that defendants violated his First Amendment right to free speech by opening his mail outside of his presence. However, the court held that defendants are entitled to qualified immunity with respect to plaintiff's unreasonable search and seizure claim under the Fourth Amendment where, defendants have met their burden to show that their actions did not violate clearly established law. Finally, the court held that plaintiff forfeited his claims regarding his First Amendment right of access to the courts and his Sixth Amendment right to the effective assistance of counsel by failing to raise them in his informal brief. Accordingly, the court affirmed in part, reversed in part, and remanded.
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