Crawford v. Littlejohn, No. 19-1949 (7th Cir. 2020)
Annotate this CaseAn Indiana prison disciplinary board concluded that Crawford had participated in an “unauthorized financial transaction” by telling Wolf, a fellow inmate, to send $400 to his mother. Wolf sent the check, which Crawford’s mother cashed. Wolf told prison officials that the payment covered the cost of drugs that Crawford had supplied. The prison’s Code B-220 bans possessing materials for, or engaging in, “unauthorized financial transactions”. Section IX of the Inmate Trust Fund Policy supplies this definition of unauthorized financial transactions: “attempting or completing financial transactions, including the sending of monies from one offender to another or the sending of monies from the family/friends of one offender to another.” Crawford claimed that the payment was for a car that Wolf’s aunt and Wolf’s daughter were buying. The prison penalized Crawford by the loss of 30 days’ good-time credit. The district judge directed Indiana to restore the 30-day credit. The Seventh Circuit reversed. The phrase “financial transactions” is broad, but broad differs from inscrutable. The rule is sweeping, not vague.
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