Brown v. Phillips, No. 14-3325 (7th Cir. 2015)
Annotate this CaseBrown, convicted of raping adult women and diagnosed with paraphilia (specifically, sexual attraction to non-consenting women) and personality disorder with antisocial and narcissistic traits, was civilly committed to the Rushville Treatment and Detention Center under Illinois’s Sexually Violent Persons Commitment Act. Brown and 17 others sued the facility’s officials and clinical staff under 42 U.S.C. 1983, alleging that policies restricting their access to movies, video games, and video game consoles violate the First Amendment. Rushville prohibited its residents from watching all R-rated movies and playing M-rated video games (may “contain intense violence, blood and gore, sexual content and/or strong language”). The policy was later changed to prohibit 353 specific movies and 232 specific games. Rushville subsequently discovered that two residents were using a video game console to access the internet to view forbidden material and banned residents from possessing video game consoles capable of accessing the internet. Brown contended that the new restrictions were retaliation against him for suing. The district court entered summary judgment for the defendants. The Seventh Circuit vacated in part, finding that the record did not contain a sufficient basis to conclude that the ban on movies and video games is reasonably related to the state’s interests in security and rehabilitation,
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