Foster v. Hughes

979 F.2d 130, 1992 WL 317229
CourtCourt of Appeals for the Eighth Circuit
DecidedNovember 5, 1992
DocketNo. 92-1253
StatusPublished
Cited by15 cases

This text of 979 F.2d 130 (Foster v. Hughes) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Foster v. Hughes, 979 F.2d 130, 1992 WL 317229 (8th Cir. 1992).

Opinion

MAGILL, Circuit Judge.

Whether state regulations that prohibit prison inmates to place their money in private interest-bearing accounts violate the prisoners’ constitutional rights is the issue presented in this case. We believe they do not, and affirm.

I.

The Missouri Department of Corrections does not allow inmates to open or continue to make deposits to checking or savings accounts held .in the individual inmate’s name.1 Instead, the Department itself keeps individual accounts for each inmate, and pools all inmate funds for deposit in a non-interest-bearing account. The bank at which the Department deposits inmate funds will not pay interest on that account because of the high volume of small transactions involved. The Department does, however, allow inmates to purchase United States Savings Bonds with funds received while in prison.

Appellants filed the instant 42 U.S.C.A. § 1983 lawsuit on September 10, 1987, claiming that the State of Missouri arbitrarily denied them the right to place their monies in private, interest-bearing accounts and required them to maintain those funds in an account that did not bear interest.2 They seek only monetary damages, not in-junctive relief.

The procedural history of this lawsuit is tortuous, to say the least; we need consider only the grant of summary judgment presently appealed. On July 23, 1991, the [132]*132magistrate judge3 recommended that the defendants’ motion for summary judgment be granted. By order filed November 29, 1991, the district court4 accepted the recommendation and granted the motion for summary judgment. This appeal followed.

II.

A. Procedural Due Process

The magistrate judge held that the inmates did not state a procedural due process claim because they could show no protected property interest and because adequate state post-deprivation remedies existed. We agree that the inmates do not state a procedural due process claim, but for a different reason. Persons are entitled to procedural due process, in the form of an individual opportunity to be heard, only when the government makes an individualized determination, not when the government commits a legislative act equally affecting all those similarly situated. See Bi-Metallic Inv. Co. v. State Bd. of Equalization, 239 U.S. 441, 445-46, 36 S.Ct. 141, 142, 60 L.Ed. 372 (1915); Minnesota Bd. for Community Colleges v. Knight, 465 U.S. 271, 283, 104 S.Ct. 1058, 1065, 79 L.Ed.2d 299 (1984); Collier v. City of Springdale, 733 F.2d 1311, 1316 (8th Cir.), cert. denied, 469 U.S. 857, 105 S.Ct. 186, 83 L.Ed.2d 120 (1984). Here, the Missouri Department of Corrections has adopted, pursuant to a legislative delegation of authority, a general rule that no inmates shall open private depository accounts. Application of this rule does not depend upon facts and circumstances surrounding each inmate. The Department’s action, sanctioned by the state legislature, has given these inmates all the procedure to which they are entitled.

B. Substantive Due Process

These inmates actually raise only a substantive due process claim: that the State of Missouri does not have the authority, consistent with the Constitution, to promulgate and enforce this regulation. To sustain this claim, the inmates must prove that (1) the Constitution grants to them as prisoners the right to earn interest on money received while in prison, and (2) the regulations in question violate this right.

Assuming, arguendo, that these prisoners have a right to earn interest on money received while in prison, we conclude that the prison regulations in question are legitimately related to valid penological purposes, and thus do not violate this right.

The Supreme Court set forth its test for the constitutionality of restrictions upon prisoners’ rights in Turner v. Safley, 482 U.S. 78, 107 S.Ct. 2254, 96 L.Ed.2d 64 (1987). First, there must be a rational connection between the prison regulation and the legitimate government interest that supports the regulation. Id. at 89, 107 S.Ct. at 2261. Second, in determining the reasonableness of a prison restriction, the court must examine whether alternative means of exercising the right in question remain open. Id. at 90, 107 S.Ct. at 2262. Third, courts must consider the impact accommodations to the right would have upon guards, inmates, and the allocation of prison resources. Id. Finally, “the absence of ready alternatives is evidence of the reasonableness of a prison regulation.” Id. Examination of the regulations in question and the justifications provided convinces us that they are reasonable.

First, the state provided several legitimate reasons supporting the regulations in question. George Lombardi, Director of the Division of Adult Institutions, Missouri Department of Corrections, stated in an affidavit that a prohibition of private depository accounts is necessary to (1) deter escapes by preventing inmate access to available funds outside the prison; (2) enforce prison rules against inmate possession of cash and prevent “strong arming” and extortion of funds from weaker inmates; (3) prevent inmate fraud upon those outside the prison; and (4) prevent use of inmate funds for illegal purposes such as [133]*133gambling, drugs or gang activities. Aff. of George Lombardi, Feb. 26, 1991. Cf. Blankenship v. Gunter, 898 F.2d 625, 628 (8th Cir.1990) (inmate accounts must be closely monitored because of legitimate security concerns such as “preventing gambling, contraband, and coerced expenditures”). Prohibiting private inmate accounts advances the legitimate penological interest in prohibiting such activities and therefore is rationally related to that interest.

Second, the prison provides inmates with an alternative method of earning interest on their funds. Inmates may purchase United States Savings Bonds, and many have in fact done so.5

Third, providing the inmates access to private accounts would seriously burden prison operations. In addition to assisting the prohibited activities mentioned above, allowing individual depository accounts would greatly increase record keeping burdens on prison staff by increasing the number of transactions between state and individual accounts. Presently, each inmate receives a monthly stipend, which is credited to his inmate aceoúnt. He then can use this account to purchase items from the prison canteen. If each prisoner had a private account, he would have to deposit money from his private account into his prison account to make such purchases. Jerome Weiler, inmate finance officer, stated that the Missouri Department of Corrections currently maintains accounts for more than 15,800 inmates, at a cost exceeding $100,000. Weiler further stated that a substantial increase in the number of transactions involving inmate accounts would require employment of additional staff and would increase program costs. Aff.

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979 F.2d 130, 1992 WL 317229, Counsel Stack Legal Research, https://law.counselstack.com/opinion/foster-v-hughes-ca8-1992.