Case 3:12-cv-00071-SI

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Filed 03/07/12

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Page ID#: 1507

Lynn S. Walsh, OSB #924955
email: walsh@europa.com
209 SW Oak Street, Suite 400
Portland, Oregon 97204
Telephone: 503-790-2772
Facsimile: 503-227-6840
Attorney for Amicus Curiae
Partnership for Safety and Justice
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
PORTLAND DIVISION

PORTLAND DIVISION PRISON LEGAL NEWS, a
project of the HUMAN RIGHTS DEFENSE
CENTER,
Plaintiff,
vs.

NO. CV 12-0071-SI
BRIEF OF AMICUS CURIAE
PARTNERSHIP FOR SAFETY AND JUSTICE
IN SUPPORT OF PLAINTIFF’S MOTION
FOR PRELIMINARY INJUNCTION

COLUMBIA COUNTY, COLUMBIA COUNTY
SHERIFF’S OFFICE, JEFF DICKERSON,
individually and in his capacity as Columbia
County Sheriff,
Defendants.

The Partnership for Safety and Justice (PSJ) submits this amicus curiae brief in support
of Plaintiff’s Motion for Preliminary Injunction. For the following reasons, this Court should
Grant Plaintiff PLN’s motion for an order preliminarily enjoining Defendants from enforcing
unconstitutional jail mail policies and practices.

Page 1

AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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I. IDENTITY AND INTEREST OF AMICUS
Partnership for Safety and Justice (PSJ) is a multi-faceted, statewide advocacy
organization based in Portland, Oregon. PSJ was founded in 1999 originally as the Western
Prison Project. It has developed a pioneering and provocative model for its work – one that
brings together all of those most directly affected by crime, violence and the criminal justice
system (survivors of crime, people convicted of crime, and the families of both) to advocate for
a system that is just and that more effectively builds safer, healthier communities.
PSJ is the first advocacy organization in the country to unite all of these constituencies.
PSJ believes this approach offers a holistic perspective and a valuable strategy for shifting
Oregon towards more effective, prevention-based approaches for creating community safety.
PSJ provides numerous resources to prisoners in both jails and prisons when such
information is requested by prisoners. One of PSJ’s programs is the Prisoner Mail Program. PSJ
receives mail from prisoners across the country requesting information on various topics
including medical issues, mental health issues, transition issues, and other inmate issues. Each
incarcerated person who writes to PSJ receives a free packet which includes a ten page
Prisoner Support Directory and a copy of PSJ’s newsletter Justice Matters. The purpose of the
mail project is to provide resources to help prisoners advocate for themselves. Last year, PSJ
sent out 1600 packets to prisoners across the country. The packets are sent in a stamped
envelope. Under Columbia County Jail’s revised policy, PSJ’s packets to Columbia County Jail
prisoners would be rejected.
This case involves a significant violation of the First Amendment rights of anyone
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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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wishing to engage in written mail correspondence with a Columbia County Jail inmate.
Because of the impact on fundamental rights of numerous individuals, and the fact that other
jails within the District of Oregon are implementing such policies, the issue raised by this case is
of great public interest. The far-reaching consequences of this case warrant the Court’s
exercise of discretion to accept this amicus brief.
II. FACTUAL BACKGROUND
The pleadings filed in this case indicate that in April 2010, the Columbia County Jail
adopted a mail policy that limited incoming and outgoing mail (excluding legal and “official”)
mail) to postcards only. When the postcard policy was announced on December 23, 2009, the
reasons given for the change were that “[t]he processing of inmate mail is very time consuming
and labor intensive,” “mail coming in sealed envelopes increases the likelihood that
contraband will make its way through the security measures we set up,” and “[g]oing to
postcards will cut down on the time we need to take in that screening process, thus saving the
taxpayer the costs involved in that screening.” Apparently, the prisoners’ and correspondents’
constitutional right of expression and privacy was not considered in adopting the postcard
policy. According to Sgt. Cutright’s declaration (Docket #30, ¶4), the revised mail policy saves
a deputy only 30 to 60 minutes a day. Sgt. Cutright fails to specify the amount of money, if
any, the policy saves.
Sheriff Dickerson’s declaration indicates that since adopting the postcard-only policy,
the policy has been revised four times. The most recent revision was made effective on
February 10, 2012, which was ten days after Plaintiff filed its Motion for Preliminary Injunction.
Page 3

AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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The mail policy used to be a simple five page easy-to-understand policy. It is now a 17-page
confusing document.
Even though the policy has gone through numerous revisions, Defendants are persisting
in retaining the postcard-only policy that forces the use of postcards for all incoming and
outgoing personal mail. Personal mail is defined as “[p]ostcards mailed to or from family,
friends, organizations, businesses, or other unofficial entities.” (Docket #32-6, Dickerson Decl.,
Ex. F, p. 2.) Under this policy, an inmate at the Columbia County Jail cannot correspond with
their employer, civil rights organizations, spouses, children, relatives, significant others, or
Amicus PSJ unless it is by postcard. In fact, under the current mail policy, prisoners at the
Columbia County Jail would be entirely precluded from participating in PSJ’s Prisoner Mail
Program.
Defendants have been revising their mail policy arguing that it renders PLN’s claims as
moot, thus allowing some of PLN’s materials to enter the jail, yet the policy continues to read
as though it excludes all businesses, civil rights organizations, and individuals’ correspondence
that is not on a postcard. The defendants correctly point out that they have the burden to
persuade the court that the challenged conduct will not reasonably be expected to recur.
(Docket #29, p. 10.) Defendants cannot meet that burden, because if they implement the
terms of their revised policy, the unconstitutional conduct will continue.

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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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III. ARGUMENT
A. The Postcard-Only Mail Policies Violate the First Amendment Rights of Prisoners
and All who Correspond with Prisoners.
The right to receive and send mail is unquestionably protected by the First Amendment.
Blount v. Rizzi, 400 U.S. 410 (1971). The law is also clear that jail prisoners generally retain the
First Amendment right to send and receive mail. See, e.g., Thornburgh v. Abbott, 490 U.S. 401,
407 (1989); Procunier v. Martinez, 416 U.S. 396 (1974), overruled in part on other grounds,
Thornburgh (noting that correspondence between a prisoner and an outsider implicates the
First and Fourteenth Amendments); Witherow v. Paff, 52 F.3d 264, 265 (9th Cir. 1995). The
Martinez case sets forth the requirements for a constitutional policy on outgoing jail mail,
while the requirements of Turner v. Safley, 482 U.S. 78 (1987), are used to evaluate the
constitutionality of a jail mail policy regarding incoming mail, Thornburgh, 490 U.S. at 413.
It is not only inmate rights, but the First Amendment rights of the many people who
correspond with them that are at stake here. Written correspondence is a two-way street, as
the United States Supreme Court has recognized:
Communication by letter is not accomplished by the act of writing words on
paper. Rather, it is effected only when the letter is read by the addressee. Both
parties to the correspondence have an interest in securing that result, and
censorship of communication between them necessarily impinges on the
interest of each. . . . The wife of a prison inmate who is not permitted to read all
that her husband wanted to say to her has suffered an abridgment of her
interest in communicating with him as plain as that which results from
censorship of her letter to him. In either event, censorship of prisoner mail
works a consequential restriction on the First and Fourteenth Amendments
rights of those who are not prisoners.
Procunier v. Martinez, supra, 416 U.S. at 408-09.
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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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In fact, there is no doubt that the postcard-only policy for both incoming and outgoing
mail will have severely harmful effects on both the prisoners and their correspondents. For
example, an inmate will not be comfortable discussing with family members sensitive topics
such as relationship issues, child-rearing issues, pregnancy, sexually transmitted diseases,
disabilities, mental health issues, medical conditions, financial issues, and even employment or
business matters, if required to do so on a postcard. The policy also prevents prisoners and
their correspondents (such as children) from engaging in entire forms of written
communications, such as expressive or artistic drawings that do not fit on a postcard. Greeting
cards are disallowed under the policy. And, the jail specifically prohibits the mailing of jail
forms (such as grievances) to someone who might be able to help the inmate complete the
form if the inmate is unable to comprehend or complete the form on his own.1 The effect, and
perhaps the purpose, of this policy is to isolate prisoners from those on the outside, and from
those who provide support to prisoners such as family members, friends, and organizations
such as PSJ.
1. The Postcard-Only Policy for Outgoing Mail is Clearly Unconstitutional.
The Defendants fail to analyze the postcard-only policy for outgoing mail under the
correct test, i.e., they incorrectly apply the Turner test to outgoing mail. As stated above, the
Thornburgh Court distinguished incoming and outgoing correspondence as follows:
[W]e acknowledge today that the logic of our analyses in Martinez and Turner

1

Section 34. f. of the postcard-only policy appears to prohibit the mailing of jail forms
to anyone, including attorneys. (Docket #32-6, Dickerson Decl. Ex. F, p. 12.)
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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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requires that Martinez be limited to regulations concerning outgoing
correspondence. As we have observed, outgoing correspondence was the
central focus of our opinion in Martinez. The implications of outgoing
correspondence for prison security are of a categorically lesser magnitude than
the implications of incoming materials.
Thornburgh, 490 U.S. at 413. Under the Martinez standard, the test for the constitutional
validity of a regulation affecting a prisoner’s outgoing mail is:
First, the regulation or practice in question must further an important or
substantial governmental interest unrelated to the suppression of expression.
Prison officials may not censor inmate correspondence simply to eliminate
unflattering or unwelcome opinions or factually inaccurate statements. Rather
they must show that a regulation authorizing mail censorship furthers one or
more of the substantial governmental interests of security, order, and
rehabilitation. Second, the limitation of First Amendment freedoms must be no
greater than is necessary or essential to the protection of the particular
governmental interest involved. Thus a restriction on inmate correspondence
that furthers an important or substantial interest of penal administration will
nevertheless be invalid if its sweep is unnecessarily broad.
Martinez, 416 U.S. at 413-14.
Restricting prisoners’ outgoing mail to postcards is simply not necessary to serve the
government’s interest in preserving order and security within the jail or crime prevention and,
therefore, cannot satisfy the Martinez standard. The postcard-only policy is completely
unnecessary because it is settled law that jail officials may inspect outgoing letters and require
that they be submitted to jail staff in unsealed envelopes to facilitate inspection. Beville v.
Ednie, 74 F.3d 210, 213-14 (10th Cir. 1996); Stow v. Grimaldi, 993 F.2d 1002, 1004 (1 st Cir. 1993).
In fact, it is somewhat incredible that the Columbia County Jail has chosen to engage in this
litigation as opposed to inspecting the mere forty pieces of outgoing mail each day that is
submitted to them in unsealed envelopes. The defendants maintain that the postcard-only
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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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policy is a cost-saving measure, yet defendants have not offered any evidence of how much
money, if any, the policy saves. See Beerheide v. Suthers, 286 F.3d 1179, 1189 (10th Cir. 2002)
(“[i]n order to warrant deference, prison officials must present credible evidence to support
their stated penological goals” (emphasis in original). In any event, a mere desire to cut down
on costs - an interest that is not unique to the correctional setting - does not and cannot satisfy
the Martinez standard for outgoing mail. See also, Battle v. Anderson, 376 F. Supp. 402, 425
(E.D. Okla. 1974), aff’d in part and rev’d in part, 993 F.2d 1551 (10th Cir. 1993) (outgoing mail
restrictions not justified when imposed “solely to serve the administrative convenience of the
defendants, without furthering any demonstrated interest in the orderly operation of the
institution or the rehabilitation of its prisoners”). The unconstitutionality of the postcard-only
policy for outgoing mail was recently recognized by the Northern District of Georgia which
ruled that a jail inmate stated a viable claim, explaining that censorship was a plausible
purpose of the policy:
-outgoing personal correspondence from prisoners-did not, by its very nature,
pose a serious threat to prison order and security. . . . [Johnson’s] allegations
state a plausible claim that the Jail’s policy violates the test. It is plausible, if not
likely, that the alleged postcard policy exists for security reasons. It also is
plausible, however, that the policy exists to facilitate improper censorship of
outgoing mail. In either case, Plaintiff may argue that Jail officials could address
their concerns by the less restrictive measure of requiring that general outgoing
mail be placed in unsealed envelopes-as they allegedly do for attorney mailinstead of altogether limiting the type and size of the medium used for such
mail. See Thornburgh, 490 U.S. at 412 (observing that “the implications for
security are far more predictable” with outgoing mail).
Johnson v. Smith, 2011 WL 344085 (N.D. Ga. 2011) (Slip Opin. 2/1/11).

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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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2. The Postcard-only Policy for Incoming Mail Fails Under the Turner Analysis.
There is no evidence that restricting to postcards all incoming mail from family, friends,
employers, employees, counselors, civil rights organizations, and the like is “rationally related
to a legitimate and neutral governmental objective.” (Turner Factor 1, 482 U.S. at 89-90).
Columbia County argues that the postcard-only policy is rationally related to a legitimate
interest in jail security, because “reviewing personal mail for prohibited content is more timeconsuming when the mail comes from an inmate or an inmate’s family and friends, as opposed
to plaintiff’s business mail, because personal mail is more likely to contain prohibited topics.”
(Docket #29, Response to Motion for Preliminary Injunction, p. 15.) Yet, under their revised
postcard-only policy, personal mail includes mail mailed to or from “family, friends,
organizations, businesses, or other unofficial entities.” (Emphasis supplied; Docket #32-6, p. 2.)
The policy makes no distinction between an inmate’s “personal” mail and “business” mail.
In any event, as discussed above and below, the postcard-only policy fails to promote
safety and security by increasing the prisoners’ stress levels, fails to provide cost savings, and
undermines the governmental objective of reducing recidivism. A jail policy that harms
governmental interests at the same time as it violates significant constitutional rights of
prisoners and all who wish to correspond with them is hardly “rational.”
Second, Turner Factor 2 considers whether alternative means of exercising the
impinged right remain open. Turner, 482 U.S. at 90. The defense argues that prisoners, their
family, and their friends have sufficient alternative avenues of communication. Again, the
defense overlooks the fact that their postcard-only policy also applies to an inmate’s mail to
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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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and from businesses and organizations which typically do not communicate by postcard.
Whether it is business mail, or family and friends’ mail, the policy’s restrictions on incoming
mail do not provide adequate alternative means of communication. Many topics can only
reasonably be discussed in closed letter correspondence if phone calls or in-person visits are
not possible. Many people are not able to make in-person visits to the jail and cannot afford
the exorbitant cost of collect phone calls. Likewise, many people only have cell phones which
do not accept collect phone calls from the jail. Thus, the only form of communication available
for these prisoners and their correspondents is by written correspondence. It is just not
possible to conduct any meaningful business or personal matter on a 5-1/2" tall postcard.
The third Turner Factor, 482 U.S. at 90, considers whether the right at issue “can be
exercised only at the cost of significantly less liberty and safety for everyone else, guards and
other prisoners alike.” There is no evidence that there would be significant costs to returning
to the policy permitting incoming letters, subject to inspection for contraband and other
criminal activity. This was the policy in place at the Columbia County Jail for many years prior
to the enactment of the postcard-only policy.
The fourth Turner Factor, 482 U.S. at 90-91, considers whether “obvious, easy
alternatives” to the challenged regulation exist. This factor is easily satisfied because the jail
can resume the constitutional policy it had for years prior to enacting the postcard-only policy.
The defense argues that due to the “time-consuming nature of screening personal mail” that
“discarding the postcard restriction would have more than a de minimis cost to the jail.”
(Docket #29, Response to Motion for Preliminary Injunction, p. 20.) Yet, Sgt. Cutright’s
Page 10

AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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declaration admits that only 30 to 60 minutes of one jail deputy’s time is saved in a day as a
result of the new policy, which would likely be only a few dollars a day. Such trivial savings
cannot justify a restriction on First Amendment rights. See Beerheide, 286 F.3d at 1192
(holding that because Department of Corrections failed to show that providing free kosher
meals to Jewish prisoners would have more than a de minimis cost in terms of finances,
staffing, and administration, it failed to show that charging for kosher meals was justified
under Turner.)
All four Turner Factors lead to the conclusion that the current policy is unconstitutional.
Enjoining it is warranted because curtailing constitutionally protected speech never advances
the public interest. ACLU v. Reno, 217 F.3d 162, 180 (3d Cir. 2000), vacated on other grounds
sub nom., Ashcroft v. ACLU, 533 U.S. 973 (2001).
B. It is Critical for Prisoners to Have Free Flowing Communication with Family,
Friends, and the Public Outside of Jail.
It is well known that prisoners’ maintenance of social connections with their family, life
partners, friends, employers, education and housing programs, and religious comfort and
sobriety support networks, among others, are essential to prisoners’ rehabilitation and
successful reintegration into society upon their release. Because the revised postcard policy
will weaken and disrupt so many significant relationships for prisoners, it is in effect a policy
that isolates prisoners at a time when they are most in need of that support.
It is already difficult for prisoners to maintain relationships with their children while
incarcerated. The revised postcard policy poses a devastating threat to this relationship. It

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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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drastically reduces the amount of written communication prisoners can have with their
children, it disallows prisoners from receiving photographs of their children (unless they go to
the expense of turning the photo into a postcard), and it also makes communication with
children who are too young to read extremely difficult since sending or receiving drawings
(unless on a postcard) is banned. The policy entirely precludes children from mailing school
work, report cards, awards, etc. to a parent.
Likewise, the postcard-only policy dismisses the needs of children of incarcerated
parents. Research has shown a close connection between parental incarceration and adverse
outcomes for children. See Justice Strategies, Children on the Outside: Voicing the Pain and
Human Costs of Parental Incarceration (Adverse outcomes for children of incarcerated parents
include an increased likelihood of school failure, unemployment, mental health problems, and
engaging in antisocial or delinquent behavior, including drug use.) The research indicates that
it is important that children have the ability to maintain regular contact with their incarcerated
parent. Having a postcard-only policy impedes the ability of children to maintain that contact.
Additionally, the inability to effectively communicate with the outside world serves to
increase stress and boredom among jail prisoners, which increases the risk of mental health
problems, or violence, with the result that the policy’s implementation may actually result in a
greater threat to the jail staff, and the community’s safety upon the prisoner’s release. Far
from satisfying the Turner test by “furthering” rehabilitation or safety, the postcard-only policy
has exactly the opposite effect. For that reason as well, it should be ruled unconstitutional.

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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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IV. CONCLUSION
For the foregoing reasons, this Court should grant Plaintiff’s Motion for Preliminary
Injunction because the injunction is necessary to serve the public interest. This is the first
court in Oregon to deal with a postcard-only policy. A preliminary injunction serves the public
interest because it will provide guidance to other jail facilities around the state and beyond as
to what constitutes a constitutional jail mail policy.
DATED: March 6, 2012

Respectfully submitted,
/s/ Lynn S. Walsh
Lynn S. Walsh, OSB #924955
Attorney for Partnership for Safety and
Justice

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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)

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CERTIFICATE OF SERVICE
I hereby certify that on the 7th day of March, 2012, I served true copies of the
foregoing AMICUS BRIEF on CM/ECF participants listed below as reflected on the Notice of
Electronic Filing:
Steven A. Kraemer
Hart Wagner, LLP
1000 S.W. Broadway, Twentieth Floor
Portland, OR 97205
sak@hartwagner.com

Katherine C. Chamberlain
MacDonald Hoague & Bayless
705 Second Avenue, #1500
Seattle, WA 98104
katherinec@mhb.com

Gregory R. Roberson
Hart Wagner, LLP
1000 S.W. Broadway, Twentieth Floor
Portland, OR 97205
grr@hartwagner.com

Jesse A. Wing
MacDonald Hoague & Bayless
705 Second Avenue, #1500
Seattle, WA 98104
jessew@mhb.com

Marc D. Blackman
Ransom Blackman LLP
1001 S.W. 5th Ave., #1400
Portland, OR 97204
mark@ransomblackman.com

Lance Weber
Human Rights Defense Center
1037 Western Ave., 2nd Floor
West Brattleboro, VT 05303
lweber@humanrightsdefensecenter.org

Dated: March 7, 2012
/s/ Lynn S. Walsh
Lynn S. Walsh, OSB #92495
503-790-2772
walsh@europa.com

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AMICUS BRIEF OF PARTNERSHIP FOR SAFETY AND JUSTICE IN
SUPPORT OF PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

LYNN S. WALSH
209 S.W. Oak St., #400
Portland, OR 97204
503-790-2772
503-227-6840 (fax)