Yang v. MO Dep't of Corr., No. 15-2231 (8th Cir. 2016)
Annotate this CasePlaintiff, a Missouri inmate, filed suit under 42 U.S.C. 1983, alleging that Missouri Department of Correction officials violated his constitutional rights when they censored his Chinese-language mail and denied him the ability to place telephone calls to China. The district court granted summary judgment to the officials. The court concluded that the restrictions were reasonably related to legitimate penological interests - specifically, security. The court also concluded that both the mail and telephone regulations were neutral and plaintiff had alternative means of communicating with outsiders. Furthermore, he also retained the ability to make domestic calls, send correspondence in English, and receive visitors; the Constitution does not require the State to bear the burden of paying for translation in any event; plaintiff has not demonstrated that there is a readily available alternative that would have eased the restriction on his ability to communicate without imposing financial burdens on the State; and thus the district court correctly rejected plaintiff's First Amendment claim based on the periods where he could neither correspond in Chinese nor international phone calls. The officials, a fortiori, did not violate Yang’s rights during periods when he could correspond in Chinese, but was prohibited from placing international telephone calls. Finally, there is no evidence that differential treatment of foreign-language mail was motivated by race or national origin or that the treatment of Chinese-language mail was a pretext for discrimination. Plaintiff's due process claim was rejected. Accordingly, the court affirmed the judgment.
Court Description: Colloton, Author, with Shepherd, Circuit Judge, and Moody, District Judge] Prisoner case - Prisoner civil rights. In action alleging prison officials unreasonably restricted plaintiff's First Amendment rights by censoring his Chinese-language mail and prohibiting international calling at the same time, the district court did not err in granting judgment for the defendants as the restrictions imposed were reasonably related to the legitimate penological objective of prison security; plaintiff had alternative means of communicating with outsiders and he failed to demonstrate that there was a readily available alternative that would have eased the restriction without imposing undue financial burdens on the state; there was no evidence that the differential treatment provided Spanish-speaking inmates was motivated by race or national origin or that the treatment of plaintiff's Chinese-language mail was a pretext for discrimination.
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