Procunier v. Martinez

The California Department of Corrections (DOC) had a policy that prisoner mail was a privilege, not a right. Pursuant to this policy, the DOC implemented rules censoring prisoners’ mail. Under the rules, prisoners could not “unduly complain,” “magnify grievances,” or express “inflammatory political, racial, religious or other views or beliefs” in letters they wrote. In addition, the prisoners were not allowed to either write or receive letters “that pertain[ed] to criminal activity,” were “lewd, obscene, or defamatory,” or were “otherwise inappropriate.” No additional rules or documentation described what these categories meant. Prison employees screened all incoming or outgoing prisoner mail except communications between a prisoner and a licensed attorney or someone holding public office. If an employee found a rule violation, the employee could return the offending letter to its author, submit a report that could lead to the prisoner losing short-term privileges, or put the letter in the prisoner’s file, which could negatively impact the prisoner’s long-term privileges or parole opportunities. Robert Martinez and other California prisoners (collectively, the prisoners) filed a class action against Raymond Procunier (defendant), the DOC’s director, in federal district court, alleging that the mail-censorship rules violated the prisoners’ First Amendment and other constitutional rights. The DOC argued that the First Amendment did not apply to prisoner mail. The DOC also claimed that the censorship served the state’s interest in maintaining internal security, external security, and prisoner rehabilitation. The district court held that the rules prohibited speech protected by the First Amendment without adequate justification, were unconstitutionally vague, and did not adequately protect the prisoners from mistakes or arbitrary censorship. The court issued an injunction preventing the DOC from enforcing the censorship rules. Procunier appealed directly to the United States Supreme Court.