People ex rel.кратно v. La Vallee, 22 N.Y.2d 413 (1968)

A prisoner has a right to communicate with the courts, executive officials regarding unlawful treatment, and their attorney regarding legal matters and treatment, but prison officials retain the right to censor communications to prevent abuse of this right.

Summary

This case addresses the extent to which a prison warden can censor a prisoner’s communications with the courts, executive officials, and their attorney. The prisoner initially sought relief for inadequate dental treatment and later challenged censorship of communications and disciplinary actions. The Court of Appeals affirmed the lower court’s finding against the prisoner on dental care and the denial of relief regarding disciplinary actions for assisting other prisoners with legal papers. However, the court addressed the censorship of the prisoner’s communications, modifying the lower court’s order to provide a more specific scope for permissible communication while affirming the warden’s right to censor irrelevant material. The court emphasizes the balance between a prisoner’s right to access the courts and the warden’s need to maintain order and security within the prison.

Facts

A prisoner at Attica Prison initiated a proceeding alleging inadequate dental treatment, censorship of communications by the warden, and disciplinary action for helping other prisoners with legal papers. The prisoner claimed the prison dentist refused to provide further care after an operation, while the dentist testified that the prisoner refused treatment. Subsequently, another dentist provided successful treatment. The prisoner was also disciplined for assisting other prisoners in preparing legal documents.

Procedural History

The Special Term denied relief based on the dental care claim and the disciplining of the prisoner. It granted relief against the warden regarding the censorship of communications. The Appellate Division affirmed the denial of relief on the first two issues but modified the Special Term’s order regarding censorship, narrowing its scope. The case then reached the New York Court of Appeals.

Issue(s)

1. Whether the Warden’s actions in disciplining the petitioner for assisting other prisoners with legal papers violated the petitioner’s constitutional rights.
2. Whether the Appellate Division’s modification of the Special Term’s order regarding censorship of the prisoner’s communications was appropriate, specifically concerning communications with executive officials and the prisoner’s attorney.
3. Whether the Warden retains the right to censor material outside the court’s specifications.

Holding

1. No, because no prisoner has a constitutional right to draw legal papers for other people.
2. Yes, because the Appellate Division’s order reasonably limited the scope of permissible communications to complaints of unlawful treatment to executive officials and legal matters and treatment to the prisoner’s attorney.
3. Yes, because the Warden must have the right to censor material which is not within the broad category laid down by the Appellate Division order.

Court’s Reasoning

The court reasoned that while prisoners have a right to access the courts, this right does not extend to preparing legal papers for other prisoners. The court declined to follow the District Court’s holding in Johnson v. Avery, emphasizing the distinction between obstructing a prisoner’s access to a court in their own right and preventing them from drafting legal documents for others. Regarding censorship, the court found the Appellate Division’s modification reasonable, allowing communication with courts about any matter, with executive officials about unlawful treatment, and with attorneys about legal matters and treatment received. The court presumed the Warden would adhere to the injunction and not censor permitted communications, especially those relating to the legality of treatment, which could be communicated to the prisoner’s lawyer. However, the court affirmed the Warden’s right to censor material falling outside the specified categories, balancing the prisoner’s right to communicate with the need to maintain order within the prison. The court stated, “It must be assumed the Warden will follow the injunction the way it reads. He will not take the risk of censoring out anything which the court has permitted, especially since this could be communicated to petitioner’s lawyer as part of the “ legality of * * * treatment “, On the other hand the Warden ought to have the right to censor material which is not within the broad category laid down by the Appellate Division order.”