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Massachusetts Supreme Court Rules Prison Mail Regulations Vague & Overbroad

Massachusetts Supreme Court Rules Prison Mail Regulations Vague & Overbroad

The Supreme Judicial Court of Massachusetts held that a prison policy governing censorship of incoming mail was unconstitutionally vague and overbroad. The court also held that another policy requiring staff approval to receive items from outside the prison did not violate the First Amendment as applied to books and other publications.

Raymond Champagne was a prisoner of the Massachusetts Correctional Institution at Cedar Junction. On June 17, 1982, a bookseller sent him two hardcover books but prison officials refused to deliver them because hardcover books were contraband and Champagne did not obtain prior written approval to receive the books.

On October 14, 1982, Champagne's lawyer sent him a package of legal documents, clearly marked "attorney-client correspondence." Over one month later, on November 19, 1982, Champagne received the material, which had been opened and inspected outside his presence.

On November 15, 1982, Champagne was mailed a paperback book but prison officials refused to deliver it because it dealt with a prison riot. That decision was later overturned, but prison officials still refused to deliver it, because Champagne had not obtained prior written approval.

Champagne brought suit in state court, alleging that the relevant prison policies violated both the state and federal constitutions. However, the Superior Court granted prison officials summary judgment.

Since the policy requiring prior written approval was content-neutral, the Supreme Judicial Court affirmed summary judgment for prison officials. "In light of the policy's insignificant infringement of First Amendment rights, the 'substitution of judicial judgment for that of the expert prison administrators on matters such as this is inappropriate.'" The court also rejected Champagne's contention that the policy was applied to him in an arbitrary and discriminatory manner.

The Court also affirmed summary judgment on Champagne's attorney-client correspondence claim because he failed to show that any of the named defendants was responsible for holding, opening and inspecting his legal mail.

The Court reversed, however, on Champagne's claim that mail rules were vague and overbroad. The Court agreed with Champagne that "by failing to specify or define 'a significant threat to the security or order,' the regulation gives too much discretion to prison employees to determine for themselves what material warrants censorship." See: Champagne v. Commissioner of Correction, 395 Mass. 382, 480 NE2d 609 (1985).

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Related legal case

Champagne v. Commissioner of Correction