Hanrahan v. Mohr

The 1993 Lucasville Prison Riot at the Southern Ohio Correctional Facility began when prisoners overpowered a guard and took his keys. Rioting prisoners ultimately took a dozen guards hostage and gained complete control of the prison’s L-block. The riot continued for 11 days; one guard and nine prisoners were murdered. Many were injured. Tens of millions of dollars’ worth of damage was done to the prison facility. Four prisoners were sentenced to death for their involvement in the riot and are classified as restricted population inmates, who “pose a direct threat to the safety of persons, including themselves, or an elevated, clear[,] and ongoing threat to the safe and secure operations of the facility. The Media Plaintiffs are professional journalists who unsuccessfully sought in-person, recorded interviews with the Prisoner Plaintiffs for the twentieth anniversary of the riot. The Prisoners and Media Plaintiffs filed suit under 42 U.S.C. 1983, alleging that the interview denials violated the First and Fourteenth Amendments because they were based on the interviews’ anticipated content. The Sixth Circuit affirmed the rejection of their claims after considering the “Turner factors” to determine that the prison regulation is reasonably related to legitimate penological interests and therefore constitutional. There is a rational connection between a policy prohibiting face-to-face interviews with Lucasville participants and the legitimate, neutral penological interest of prison security. The impact of accommodation of the right and the availability of ready alternatives also support the restrictions’ constitutionality. View "Hanrahan v. Mohr" on Justia Law