Birkley v. Ball

CourtDistrict Court, E.D. Wisconsin
DecidedSeptember 15, 2025
Docket2:25-cv-00204
StatusUnknown

This text of Birkley v. Ball (Birkley v. Ball) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Birkley v. Ball, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ______________________________________________________________________________ SYRIS T. BIRKLEY,

Plaintiff, v. Case No. 25-cv-0204-bbc

DENITA R. BALL, et al.,

Defendants. ______________________________________________________________________________

DECISION AND ORDER ______________________________________________________________________________

Syris Birkley is incarcerated at the Milwaukee County Jail and representing himself in this 42 U.S.C. §1983 case. He is proceeding on a First Amendment claim in connection with allegations that, pursuant to a Milwaukee County Jail policy, his incoming mail is scanned and electronically saved by ViaPath Technologies and that he can only view digital copies of his mail on a jail-issued tablet. Dkt. No. 7 at 5. On May 27, 2025, Milwaukee County and Milwaukee County Sheriff Denita Ball filed a motion to dismiss. Dkt. No. 17. That same day, ViaPath Technologies also filed a motion to dismiss. Dkt. No. 21. For the reasons explained below, the Court will grant the Defendants’ motions. The Court provided a thorough summary of the complaint’s allegations in its March 26, 2025, screening order, so it is unnecessary to do so in this decision. Dkt. No. 7. As noted in the screening order, it is difficult to identify the complaint’s factual allegations because they are buried in pages of legal analysis and case citations, none of which are required to state a claim under Fed. R. Civ. P. 8.. As best as the Court could tell, the primary focus of the complaint was Birkley’s concerns about the handling of his mail. Specifically, Birkley states that, since October 29, 2024, his “legal and regular mail” has been opened and scanned without his consent and outside of his presence. Although Birkley does not describe the contents of the mail that he characterizes as “legal mail,” he suggests that many, if not all, of the mail items were sent by courts or public agencies. The Court also notes that, per the Wisconsin Circuit Court Access website, Birkley is representing himself against criminal charges pending in Milwaukee County Case No. 2024CF4650, and he has not identified any lawyer with whom he is in contact about that or any

other case. Birkley also alleges that ViaPath Technologies scans and stores all incoming mail, which inmates must then view on a jail-issued tablet. Birkley explains that he chose to opt out of the jail’s mail policy, but Defendants will not provide him with his mail or hard copies of his mail. The Court allowed Birkley to proceed on a claim based on allegations that an agreement between Milwaukee County and ViaPath Technologies authorizes ViaPath Technologies to scan all incoming mail and provide digital copies to inmates, which may be accessed on a jail tablet or at a jail kiosk. The Court concluded, however, that Birkley did not state a claim based on allegations that his non-legal mail was opened and read outside of his presence because the First Amendment does not prohibit jail officials from doing so. See Wolff v. McDonald, 418 U.S. 539,

575-76 (1974); see Gaines v. Lane, 790 F.2d 1299, 1304 (7th Cir. 1986) (“we held that it was entirely proper for prisoner officials to inspect mail for contraband”). The Court also concluded that Birkley failed to include sufficient factual allegations from which the Court could reasonably infer that his “legal mail” was being opened and read outside of his presence. The Court explained that just because mail concerns legal issues does not mean that it is “legal mail” deserving of heightened protections under the First Amendment. Without factual allegations supporting an inference that privileged communications between Birkley and his lawyer were read outside of his presence, Birkley failed to state a claim. See Guajardo-Palma v. Martinson, 622 F.3d 801, 803- 04 (7th Cir. 2010). Defendants filed motions to dismiss on May 27, 2025. The County Defendants’ primary argument is that Birkely fails to state a claim because the First Amendment protects an inmate’s free expression and access to mail; it does not protect privacy. Indeed, it has long been held that “the interest of the state in monitoring the nonprivileged correspondence of the pretrial detainees justifies the minor burden that it places on their freedom to communicate with friends and

relatives.” Smith v. Shimp, 562 F.2d 423, 425 (7th Cir. 1977). Defendants explain that the jail’s policy does not prohibit communication or censor communication; it merely converts hard copy mail into a digital format viewable by an inmate on a jail tablet and/or jail kiosk. As noted in the policy, see Dkt. No. 18-1 at 1, this conversion from paper to digital format promotes the safety and security of the facility and prevents the introduction of contraband, namely of drugs applied to paper. Birkley argues in response that, because he is “not a prisoner” but “a pretrial detainee, [he] retain[s] all [his] rights.” Dkt. No. 35 at 2-3. He also argues that mail from courts, court officials, and government agencies should not be screened but should be treated as privileged

communication similar to how communications between inmates and their lawyers are treated. Id. at 4. Both arguments fail. First, courts have consistently held that “[n]either the right of free speech nor the right of privacy is absolute, but the interests they protect must be considered against important governmental interests in regulation.” Smith, 562 F.2d at 425. Jail officials have a legitimate interest in maintaining the safety and security of the jail, and the appellate court long ago explained that policies that deter a substantial threat to jail security justify the burden imposed on a pretrial detainee’s freedom to communicate in a private manner. Id. at 426. As the sophistication of those desiring to break the law has evolved, so too have the efforts of jail officials to maintain security by keeping out contraband. It is no secret that bad actors have sought to introduce drugs into jails and prisons by many means, including coating paper that is then smoked, chewed, or otherwise consumed. Jails and prisons have therefore been forced to develop policies that allow inmates to access their mail while depriving bad actors the opportunity to introduce drugs into the jail. The Court concludes that, given these circumstances, the burden imposed on inmates from having to

access their mail in a digital format rather than in hardcopy is justified. After all, as the Supreme Court has acknowledged, “the problems that arise in the day-to-day operation of a corrections facility are not susceptible to easy solutions. Prison administrators therefore should be accorded wide-ranging deference in the adoption and execution of policies and practices that in their judgment are needed to preserve internal order and discipline and to maintain institutional security.” Bell v. Wolfish, 441 U.S. 520, 547 (1979). Next, contrary to Birkley’s suggestion, it is well settled that not all mail that involves a legal issue is considered “legal mail” for First Amendment purposes. There is no constitutional harm when public documents that “prison officials have as much right to read as the prisoner” or

“routine and nonsensitive” nonpublic documents are opened outside the prisoner’s presence.

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