7th Circuit finds judge misapplied prison rule without explanation

A judge who overturned prison discipline for an inmate who wrote an unauthorized check to a fellow inmate’s family member left a panel of the 7th Circuit Court of Appeals puzzled in a brief reversal Monday.

The case involves James Crawford, an inmate at Wabash Valley Correctional Facility, who told fellow inmate Scott Wolf to send a $400 check to Crawford’s mother, Becky Crawford. Wolf told prison officials that the payment covered the cost of drugs that Crawford supplied.

Citing prison code B-220, which, among other things, bans “family or friends of Offender A sending money to family of friends of Offender B,” Crawford was disciplined and penalized by the loss of 30 days’ good-time credit, but Indiana Southern District Senior Judge William Lawrence granted Crawford’s habeas petition, reversing the discipline.

“For what it may be worth, we doubt that the state officials have misunderstood the prison’s rules,” Judge Frank Easterbrook wrote for the panel, reversing and reinstating Crawford’s discipline. “The definition covers ‘attempting or completing financial transactions, including’ three examples (emphasis added). The examples illustrate some applications. The judge did not explain why he read this definition to cover only the examples, as opposed to the full spectrum of ‘financial transactions’ that the prison has not authorized.

“Crawford says that the structure of this definition — a broad term (‘financial transactions’) followed by three non-exclusive examples — makes it unconstitutionally vague. We do not agree,” Easterbrook continued. “The phrase ‘financial transactions’ is broad, but broad differs from inscrutable. The rule is sweeping, not vague. People of common understanding can see what is forbidden.”

The case is James Crawford v. Frank Littlejohn, Deputy Warden, Wabash Valley Correctional Facility, 19-1949.

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