Reynolds v. Quiros, No. 20-1158 (2d Cir. 2022)
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Plaintiffs, seven inmates in Connecticut state prison facilities, filed suit against DOC alleging that the 2012 revised Administrative Directive, which limits access by inmates to pictorial sexually explicit materials, violates their First Amendment rights. Plaintiffs also allege that the prison regulation's exception for material that qualifies as "literary, artistic, educational or scientific in nature" is unconstitutionally vague.
The Second Circuit affirmed the district court's decision in favor of the DOC, discerning no clear error as to the district court's factual findings in light of the trial record. The court also concluded that the district court, based upon its factual findings, properly held that A.D. 10.7 is reasonably related to legitimate penological objectives—namely, promoting a non-hostile work environment for DOC staff, enhancing the safety and security of DOC facilities, and facilitating the rehabilitation of sex offender inmates—and does not violate the First Amendment. Furthermore, the court concluded that the district court correctly determined that the regulation, including the exception, is neither unconstitutionally vague on its face, nor unconstitutional as applied to plaintiffs.
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