Chapman v. San Mateo County

Background

Marcel E. Chapman, an inmate at Maple Correctional Facility, filed this self-represented action under 42 U.S.C. § 1983. He alleged that San Mateo County violated his First Amendment right to receive mail by prohibiting inmates from receiving handwritten letters. The court had previously found that allegation sufficient to state a legally recognizable First Amendment claim.

The County’s mail procedures allowed regular incoming mail to be screened for contraband. The procedures also required most incoming mail to be sent to a post-office box, where it was scanned and made available electronically through a tablet and the Smart Jail Mail application. Mail sent directly to a jail facility was returned to the sender. The court noted that the County had no policy prohibiting inmates from receiving handwritten mail.

The record also described a February 3, 2021 incident involving two envelopes. A correctional officer found 13 film strips of Suboxone under the seal of one envelope and confiscated another envelope addressed to Chapman because the officer suspected the envelopes were connected. Chapman stated that, apart from those envelopes, he received his mail after it was found to be free of contraband.

The Motion for Summary Judgment

Summary judgment is appropriate when the evidence shows no genuine dispute about a fact that could affect the result and the moving party is entitled to judgment under the law. The County argued that Chapman had not completed the required jail grievance process and that he had not shown a constitutional violation.

In opposing the motion, Chapman acknowledged that the County did not have a policy completely prohibiting handwritten mail. He instead challenged the policy requiring handwritten mail to be scanned and delivered in electronic form. He objected to receiving mail through a third party on a tablet. He also stated that he had appealed his grievance but had not received a response, although his operative complaint acknowledged that he had not completed the grievance process.

Court’s Analysis

The court treated Chapman’s new challenge to receiving handwritten mail only in electronic format as different from the claim stated in his operative complaint. The court found it undisputed that inmates in San Mateo County correctional facilities could receive handwritten mail, although in electronic format. Because the challenged policy did not deny inmates the ability to receive handwritten mail, the court held that San Mateo County had not violated Chapman’s First Amendment right to receive mail on the claim before it.

Because the claim failed on the merits, the court declined to decide whether Chapman satisfied the Prison Litigation Reform Act’s exhaustion requirement. The court also stated that a fellow inmate’s declaration about that inmate’s own alleged mail deprivation did not establish the challenged County policy and that Chapman could not bring constitutional claims based on injuries allegedly suffered by the fellow inmate.

Disposition

The court granted San Mateo County’s motion for summary judgment. It also granted Chapman leave to amend his complaint to challenge the policy requiring handwritten mail to be received electronically. The court directed him to file an amended complaint within 28 days if he wished to pursue that claim and stated that failure to do so would result in dismissal of the action without further notice.