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Broader than Necessary Jury Instruction Requires Reversal in Prisoner's First Amendment Violation
Broader than Necessary Jury Instruction Requires Reversal in Prisoner's
First Amendment Violation Claim
The Fourth Circuit Court of Appeals held that it was a reversible error to
give a jury instruction requiring that any prison restriction be no broader
than necessary, rather than reasonably related to a legitimate security
interest. This 42 U.S.C § 1983 action was filed by a prisoner at North
Carolina's McCain Correctional Center, alleging the prison's superintendent
violated his First Amendment right to participate in an Islamic religious
service known as Jumu'ah. The matter proceeded to a jury trial, and the
jury awarded the prisoner $700 in compensatory damages and $3,000 in
punitive damages on its finding of a constitutional violation.
On appeal, the superintendent argued that the jury instruction that placed
the burden on him to prove the restriction was no broader than necessary
to serve the interest asserted to impose the restriction was reversible
error. The Fourth Circuit agreed, as that instruction is equivalent to the
least-restrictive test condemned in Turner v. Safely, 107 S.Ct. 2254
(1987), which ruled that when a prison regulation impinges on inmates'
constitutional rights, the regulation is valid if it is reasonably related
to legitimate peneological interests. The Court remanded for a new trial
because of the erroneous instruction.
The Court also found that the district court improperly excluded testimony
as hearsay. Specifically, the Court excluded the prison's Islamic
Coordinator from relating conversations with the superintendent that
related to the assessment for security risks and the need for restrictions
on Jumu'ah. The Court found the superintendent was not trying to establish
by this testimony that the prisoner had actually created certain security
problems at other prisons, but rather his purpose was to show the
superintendent had been told by the Coordinator that the prisoner's conduct
implicated security concerns. Because this testimony was relevant to the
issues, it was relevant and should not have been excluded at trial. The
Court ordered the testimony be allowed at a new trial, and the district
court should consider the issue of qualified immunity prior to trial. The
matter was reversed and remanded. See: Lane v. Griffin, 834 F.2d 403 (4th
Cir. 1987).
First Amendment Violation Claim
The Fourth Circuit Court of Appeals held that it was a reversible error to
give a jury instruction requiring that any prison restriction be no broader
than necessary, rather than reasonably related to a legitimate security
interest. This 42 U.S.C § 1983 action was filed by a prisoner at North
Carolina's McCain Correctional Center, alleging the prison's superintendent
violated his First Amendment right to participate in an Islamic religious
service known as Jumu'ah. The matter proceeded to a jury trial, and the
jury awarded the prisoner $700 in compensatory damages and $3,000 in
punitive damages on its finding of a constitutional violation.
On appeal, the superintendent argued that the jury instruction that placed
the burden on him to prove the restriction was no broader than necessary
to serve the interest asserted to impose the restriction was reversible
error. The Fourth Circuit agreed, as that instruction is equivalent to the
least-restrictive test condemned in Turner v. Safely, 107 S.Ct. 2254
(1987), which ruled that when a prison regulation impinges on inmates'
constitutional rights, the regulation is valid if it is reasonably related
to legitimate peneological interests. The Court remanded for a new trial
because of the erroneous instruction.
The Court also found that the district court improperly excluded testimony
as hearsay. Specifically, the Court excluded the prison's Islamic
Coordinator from relating conversations with the superintendent that
related to the assessment for security risks and the need for restrictions
on Jumu'ah. The Court found the superintendent was not trying to establish
by this testimony that the prisoner had actually created certain security
problems at other prisons, but rather his purpose was to show the
superintendent had been told by the Coordinator that the prisoner's conduct
implicated security concerns. Because this testimony was relevant to the
issues, it was relevant and should not have been excluded at trial. The
Court ordered the testimony be allowed at a new trial, and the district
court should consider the issue of qualified immunity prior to trial. The
matter was reversed and remanded. See: Lane v. Griffin, 834 F.2d 403 (4th
Cir. 1987).
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Related legal case
Lane v. Griffin
| Year | 1987 |
|---|---|
| Cite | 834 F.2d 403 (4th Cir. 1987) |
| Level | Court of Appeals |
| Conclusion | Jury Verdict |
| Attorney Fees | 0 |
| Damages | 3700 |
| Injunction Status | N/A |
Lane v. Griffin, 834 F.2d 403 (4th Cir. 12/03/1987)
[1] UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
[2] No. 87-7530
[3] 1987. 834 F.2d 403
[4] decided: December 3, 1987.
[5] LLOYD STEVEN LANE, PLAINTIFF-APPELLEE,
v.
J. H. GRIFFIN, DEFENDANT-APPELLANT AND MUHAMMAD NUBEE, CHAPLAIN; RAE MCNAMARA, DIRECTOR OF PRISONS, JAMES WOODARD, SECRETARY OF CORRECTIONS, DEFENDANTS
[6] Appeal from the United States District Court for the Middle District of North Carolina, at Rockingham. Richard C. Erwin, U.S. District Court Judge, CA-84-920-R.
[7] Sylvia Hargett Thibaut, Assistant Attorney General (Lacy H. Thornburg, Attorney General; Lavee H. Jackson, Associate Attorney General on brief) for Appellant.
[8] Martha Elizabeth Johnston for Appellee.
[9] Reversed and Remanded.
[1] UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
[2] No. 87-7530
[3] 1987. 834 F.2d 403
[4] decided: December 3, 1987.
[5] LLOYD STEVEN LANE, PLAINTIFF-APPELLEE,
v.
J. H. GRIFFIN, DEFENDANT-APPELLANT AND MUHAMMAD NUBEE, CHAPLAIN; RAE MCNAMARA, DIRECTOR OF PRISONS, JAMES WOODARD, SECRETARY OF CORRECTIONS, DEFENDANTS
[6] Appeal from the United States District Court for the Middle District of North Carolina, at Rockingham. Richard C. Erwin, U.S. District Court Judge, CA-84-920-R.
[7] Sylvia Hargett Thibaut, Assistant Attorney General (Lacy H. Thornburg, Attorney General; Lavee H. Jackson, Associate Attorney General on brief) for Appellant.
[8] Martha Elizabeth Johnston for Appellee.
[9] Reversed and Remanded.