Hogue v. Canyon County Sheriff's Department

CourtDistrict Court, D. Idaho
DecidedSeptember 17, 2025
Docket1:25-cv-00212
StatusUnknown

This text of Hogue v. Canyon County Sheriff's Department (Hogue v. Canyon County Sheriff's Department) is published on Counsel Stack Legal Research, covering District Court, D. Idaho primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hogue v. Canyon County Sheriff's Department, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

BRIAN E. HOGUE,

Case No. 1:25-CV-00212-DCN Plaintiff,

INITIAL REVIEW ORDER v. BY SCREENING JUDGE

CANYON COUNTY SHERIFF

KIERAN DONAHUE,1

Defendant.

Plaintiff Brian E. Hogue, a prisoner in custody of the Idaho Department of Correction, has filed a civil rights Complaint, subject to review by the Court to determine whether it should be dismissed under 28 U.S.C. §§ 1915 or 1915A. Dkt. 2. The Complaint regards an alleged First Amendment access to reading materials claim arising from Plaintiff’s incarceration at the Canyon County Jail. After Plaintiff filed his Complaint, he was transferred from the Canyon County Jail to an Idaho Department of Correction prison facility. As a result, he has withdrawn all claims except personal capacity claims against Canyon County Sheriff Kieran Donahue. Dkt. 4. REVIEW OF COMPLAINT 1. Standard of Law for Review of Complaint The Court is required to review complaints filed by prisoners seeking relief against

1 Case caption modified to reflect that only one defendant remains after voluntary dismissal of other defendants. a governmental entity or officer, to determine whether summary dismissal is appropriate. The Court must dismiss a complaint or any claim that states a frivolous or malicious claim, that fails to state a claim upon which relief may be granted, or that seeks monetary relief

from a defendant who is immune from such relief. 28 U.S.C. §§1915(e)(2)(B), 1915A(b). Plaintiff brings his claims under 42 U.S.C. § 1983, the civil rights statute. To state a claim under § 1983, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991).

A complaint fails to state a claim for relief under Rule 8 of the Federal Rules of Civil Procedure if the factual assertions in the complaint, taken as true, are insufficient for the reviewing court plausibly “to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 2. Discussion

Plaintiff alleges that Canyon County Sheriff Kieran Donahue has promulgated a jail policy prohibiting inmates from ordering non-religious books from outside vendors, while allowing inmates who practice religious beliefs to order religious books from outside vendors. Plaintiff asserts this practice violated his First Amendment and Fourteenth Amendment rights when he was housed at the Canyon County Jail.

Plaintiff will not be permitted to proceed on his Complaint for the following reasons, but he may file an amended complaint. A. First Amendment Claim The context of an inmate’s exercise of free speech determines how much protection is afforded the speech. Incarceration is a relevant context. In Turner v. Safley, 482 U.S. 78 (1987), the United States Supreme Court examined the free speech issue in the context of prison officials prohibiting correspondence between inmates residing at different state

institutions. The Court instructed the federal district courts to review four factors when a prison regulation or practice impinges on a First Amendment right of a prisoner: (1) whether there is a “valid, rational connection between the prison regulation and the legitimate governmental interest put forward to justify it”; (2) whether “there are alternative means of exercising the right that remain open to prison inmates”; (3) what

“impact accommodation of the asserted constitutional right will have on guards and other inmates, and on the allocation of prison resources generally”; and (4) whether “ready alternatives” at a “de minimis cost” exist, which “may be evidence that the regulation is not reasonable, but is an exaggerated response to prison concerns.” Id. at 89-93 (internal quotation marks omitted).

When considering a prison rule or regulation under Turner, a court must review both (1) the facial validity of the regulation under the four Turner factors and (2) whether the regulation was unconstitutional as applied to the inmate by examining “whether applying the regulation to th[e] speech . . . was rationally related to the legitimate penological interest asserted by the prison.” Hargis v. Foster, 312 F.3d 404, 410 (9th Cir. 2002).

Plaintiff asserts that his First Amendment freedom of speech right was violated because he was denied the opportunity to read, based on an incident in which he was not permitted to order secular books into the jail from an outside source. Presently, the jail asserts that its library system is as follows: “Books are no longer accepted by the jail. The new tablet system has an extensive library of over 7,000 books that are available to inmates.” See https://www.canyoncounty. id.gov/elected-officials/sheriff/detention-center/ (accessed 7/18/2025). It is unclear whether this system was in effect during Plaintiff’s stay

at the jail, whether it was free of charge, or whether a different free library from which to borrow books was in place. A jail policy prohibiting the ordering in of non-secular books is subject to the Turner v. Safley test. See Temple v. Oconee Cnty., No. CA 6:13-144-JFA-KFM, 2014 U.S. Dist. LEXIS 124756, 2014 WL 4417702, at *5 (D.s.c. Sept. 8, 2014), aff'd, 595 F. App'x 246

(4th Cir. 2015) (finding a rational connection between a restriction on reading materials and the legitimate governmental interest in institutional safety and security, and finding that facility provided an alternative means of exercising First Amendment right where the jail provided legal materials through an institutional law library); McCormick v. Reinkey, No. 1:21-CV-00454-DCN, 2022 U.S. Dist. LEXIS 82630, 2022 WL 1422925, at *4 (D.

Idaho May 5, 2022) (holding that “[p]rohibiting books being sent directly to inmates, but instead requiring them to be sent to the jail library, is reasonably related to the legitimate— indeed, the compelling—interest in jail security and safety.”) Plaintiff may file an amended complaint providing factual allegations that address these case holdings and the Turner factors, or he may voluntarily dismiss this claim.

B. Fourteenth Amendment Equal Protection Claim An equal protection claim may be established by showing that similarly situated individuals were intentionally treated differently without a rational relationship to a legitimate state purpose. Village of Willowbrook v. Olech, 528 U.S. 562, 564 (2000); Lazy Y Ranch Ltd. v. Behrens, 546 F.3d 580, 592 (9th Cir. 2008). Plaintiff asserts that his equal protection rights were violated when Defendant permitted inmates to order in religious books, but “non-religious” inmates could not order

in secular books.

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Related

Turner v. Safley
482 U.S. 78 (Supreme Court, 1987)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
David Mathis v. Jennifer Monza
530 F. App'x 124 (Third Circuit, 2013)
Lazy Y Ranch Ltd. v. Behrens
546 F.3d 580 (Ninth Circuit, 2008)
Village of Willowbrook v. Olech
528 U.S. 562 (Supreme Court, 2000)

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Hogue v. Canyon County Sheriff's Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hogue-v-canyon-county-sheriffs-department-idd-2025.