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A Report on the Oppression of the Political Prisoners within Pontiac Correctional Center 2012  Written by: Matthew Smith (on behalf of 8.0.B.)
Contents Introduction Whatis S.0.8.2 Fiest Amendment: Access to Reading Maerial First Amendment: Censorship of Mail First & Fourteenth Amendinents: Access to Courts First & Fourteenth Amendments: Freedom of Religious Activity Education Eighth Amendment: Protection From Physical Brutality  Eighth Amendmier  : Right to Decent Conditions in Prison Sanitation Lighting Fouricenth Amendment: Du¢ Process Meatloaf Suip-Out Conclusion Injunctive Reliet References  About the Author  [T L  b3  ®  pe 14 pe 14  e 1S  ] S  2 3  pe 19  pg 20  Edited by Anthony Rayson on November Léth; 2013  Published & Distributed By:  South Chicago ABC Zine Distro | POB 721/ Homewood, IL 60430 @nticopyright - free to prisoners - Each One, Teach One
Tntroduction 2  This report was written to shed light on the oppression of the politcal prisoners within Pontiac Correctional Center. This oppression is perpetuated knowingly, willngly, and continuously by the Pontiac Correctional Center Officials whose job and duy is (0 house. care, and rehabiliate prisoners.  It the hope of the author tha this report wil open the eves of saiety 1o the inhumane conditions and treatment of prisoners - speificaly those who are confined in Pontiac Correctional Center. Purthermore,the author hopes that after their eyes have been opened socicty will nite and demand that these oppressive actions be stopped.  ‘Altbough prisonersare incarcerated for vaious crimes they stil have righs. Rights that are being violated and ignored hy Pontiac Correctional Center Offcials. Hopefully. with the hlp of the masses, that will soon end.  Whotis SO.R?  “The Soldirs of Bondage (5.0.8.) s a communist revoluionary politial movement that i against Imperial Capitalism in all of it forms.  “This report contains ways that the current capitalist system oppresses the people of Amerikka. However, it i by no means every way tha the people are oppressed.  5.0.B.i ot a gang nor does it advocate gang activity. Instead, $.0.5. educates the ‘masses about their oppression and advocates peaceable resistance (such as the ‘onstruction of this report). The movement was founded by Matthew Smith on July 2, 2011 within Pontine Correctional Center Segregation. The goals of §.0.B. are as follows; 1.) To end the opression of the peaple perpetuated by the Amerikkkan govemment: 2) To end capialism; and 3 To implement communism into the government,  Again, S.0.B.s not a gang! 5.0.B. does not ndvoeate violence (armed-resistance) but peace (passive-resstance). It s the i of §.00.. t counter oppression with iberation and true-equality for all!  First Amendment: Accs 0 Reading Material  The First Amendment protects a prisoner’sright o obiain and possess reading material Prison offcials cannot ban any publication unless they can show “legiimate govermment interest” in prohibiting the material. See Turner vs. Safley, 482U.5. 78 (1978): wnd Thornburgh. Abbot, 490 U.S. 401, 404 (1989).  However, just because prison officials have theright o ban publications that does not ‘mean tha they can abuse thatauthority. An example of Pontiac Correctional Center Officials abuse of discretion s the construction and maintenance of st of publications thathave been prokibited by said official.  A prison cannot maintain a st of excluded publications or decide that no materials from a paticular organization willbe allowe . It must decide about each book o ‘magazine on n case-by-case-basis. This holds true cven for books and magazines that prison offcils know have been banncd in the past. Sec Williams ve. Brimeyer, 116 F. 3d 351(8* Cir. 1997); and DR 525.210(a).
Prison offcils cunnol ensor nterial just begause it contains eligious, philosophucal, poliical, socia,sexual, or unpopulas o repugrant content. They can only censor moterial i they belive i willincite disonde or violence, o it will huta prisoner’s ¢  rehubiltation.” Thornburgh vs. Abboit. Yet, even though the law gives prisoners reasonble protection, Pontiae Correctional Center Oficials knowingly, willngly, and continuously infrnge on prisoners’ rights. The probibition of Machiavelli, Robent Greene, Sun T, Clausewitz, ec... are in Violaton of the procedures set forth in Turner. Turner asks four (4) questions of the prison offcials banuing of publications. They are as follows;  e 10 8 legiimate, neutal govermment interest? sother way for you 10 exercisc your  1) Isthe regulation reasonably rc  2) Does the regulation leave o Consitutonal Rights?  3.) How does the regulaion impuct other prisoners, pison guards or offcils and  prison resources? 4 Are there obvious, casy altemalives o the regulation that would not restict your  righto free expression”  1 egands o the suthorspreviously menionca 1 will now respond 0 ach ofthe Turer questons in ull.  1) The baaning of Machiavelli, Grecuc, Teu, and Clausewitz ae not related o any legitimate, neutral government inteest. Pontiac Correctional Ceater Officials claims that the material writien by them is  “sccuriy threat” 10 he institution; but they do not  fy how they are  threat son officialscan *...censor material i they believe it willinite disorder ot violence,  or will hurta prisoner’s rehabilitation.™ Thornburgh vs. Abbort. - Emphasis mine. throughout.  None of these authors advocate violence or Jisorder. They are historians and/or philosophers who ponder many things such ss life, war, ove, success, and sociey. They o not encouruge people 1o bar armis against the governmen noe do they suggest that violence s the answer o society’s problems.  They do not incte disorder, violence, or bur a pisoner’s rehabilitation. Thus, Pontiac Corrctionsl Center Officials fl the first Tumer Question.  2. The bansing of Machisvell, Greene, Tzu, and Clausewitz does notleave open ‘another way for prisoners to obtain matcral witin by them and therefore prisoners cannon excreis their Consitutional Rights 1 have access (0 reading materialas set forth inthe First Amendment.  Being tha their works have been probibited prisoncrs cannot receive copics of them in any way. Prisoners cannot have family and frends print matecial of o the intemet and Sent o them because that would be a violation of Department Rules 504 209 Dangerous Written Material; 504,308 Contraband or Unauthorized Property; 504.310 Abuse of Privileges: S04.403 Disobeying a Direct Order; and 504.404 Violation of Ruls.  “These violations would resultin a Do 0317 Disciplinary Reportbeing witien which would resultin loss of privilegs, loss of good time, demotion of grade, and segregation time.  “Therefore,the bunning of said authors docs not allow prisoners o obtain thir works by other means bocause their material has becn banned in i’s entisey. Thus, Potiac Correctional Ceater Official fal the sccond Tumer Question as well
3) The baning of Machinvell, Greene, Tz, and Clauscwitz et ll prsoners because it preveats them from pursuing an cducation in cerainareas. 12 prisoner wished 10 obtain a degree in poltical science he would be unable 0 do 5o because he ‘would inevitably come across such theorisftopics s war, society, strategy, taiics, and revolution which are the main topcs wrtten bout by the above authors who have been banoed.  Imagine. A prisoner pays for a correspondence cours in poliical science and as part of hislesson must read Clausewitz, Tzu, Machiaveli, o Greene. He would be unabie to do 50 due 0 the baning of them and that would obstructhim from finishing and obtaining his degre.  “The baning of Machiaveli, Green, Tz, and Clauscwitz does not impact prison guards, offcials, o prison resources in any way. Whether or not  pisoner reads their work the prison willconinue fo funcion safel and successfuly hecause ther matrial does not advoeate disorde, violeace, or harm a prisoner’ rehabiliaion.  ‘Therefore, th prohibition o these authors i nothing mor than an abuse of power and  way of oppresing prisoners within Pontioc Correctional Center. Thus, Pontinc Correctionl Ceater Officials failth third Tumer Question also  4) Yes. There i an easy, obvious altemative (o the banning of Machiavelli, Greene, Tzu, and Clausewitz. Pontiac Corrctional Center Officials ban all works refated to war, sratgy, tactic, and revolution.  ‘The altemative (0 this i 0 allow in books and magazines that discuss the theory of these topics and 0 ban those that advocate the use of them. There is a mass difference. between discussing the theory or history of war and discussing the desire to start a war.  However, Pontiac Correctional Center Officials refuse to iz this altemative and ‘contnue to sbuse thei authority and oppress the prisoners withn thei care. Ths, Poniac Correctional Center Offcial il the fourth, and final, Turmer Question as well  As dictated ahove, Pontiac Correctional Center Officials “Tumer Questions satisfactorily.  Machiavelli, Greene, Tz, and Clauscwitz are not the only authors victimized by Pontinc Correctional Officials abuse of power. [ have used them only as examples of this oppression and acknowledge tha they are only a fev of the authors who are banned illgally.  to meet any of the four (4)  First Amendment: Censorship of Mail  “The First Amendment protects prisoners” right 0 send and eceiv letters. Generaly prson oficials have the authority (0 censor incoming and outgoing mal for the sake of sccurity. However, his does not petain o lgal mail which is (o remain confdential See Gates v. Collier, 301 F.2d 1291 (5 Cr. Sept. 20, 1974): and Procumier v Martine, 416 US. 396 (1979)  “The court decided n Collier tha legal mail consistsof any mail addressd 10 or rom ) All Federal Offiials including the President o the United Stics, any sentor or ‘congressman, and officils of any Urited States ageney or department;l state officials includingthe Governor, membersof the sate Sene nd House of Representatves, and officals of any satc agency or department.™
Pouic Comectional Center Officals bave & repetive istory of tumpering with prisoncrs” incoming ad ougoing leal mail. This Ganpering obsircts a prisoner’s right 10 have aceess o the courtsund non-censored legal mail. Sec Bach vs. People o the Suate of linois, 504 F. 2d 1100 (7* Cir. 1974); and Adams vs. Carlson, 488F. 2d 619 (7 Cir. 1973).  In Bach the court sid, “We think dat contact with an atorney and the opportunity (o communicat privatly is  vital ingredicnt o the ffecive assistance o counsel aod access 1 the courts” See also Moore vs. Ciccone, 8 Cir. 1972, 459 F.2d ST4; and McCray vs. Sullivan, 5™ Cir. 1975, 509 F.2d 1332.  Indeed, in MeCray the cout found that .. inmate’s right of unfetered aceess (0 the courts i a fundamental a ightas any other he may bold... Al othe rights ae lusory without it  O page 17.0fthe Pontia Correcional Certer Oreniation Marual it st n scion ) Ml Service:  Offenders may reive s ulinted b of s from anyone except a offnder in snothe insitadon. s case, permisson ust b ganied by both failics wardas. i will b openc snd cxamined fo conrabund, eccpt legal il which will be apened by th officr delveingthe sl infront fthe ffnder, ad examined for Contraband. The offende is requird 0sig sl satingthe ol was unopeaed il the officer openod it i his presence. — Emphisis mie troughout.  i saepent s in ccordance 10 law. Sec Castill v, Cook Courty Mail Room, 990 F2d304 (P Cir. 1999)  However, even though these regulons e within th rle book,the ffcals of Poniac Coretional Centerdo ot alvays comply it hen  There are severl instances when prisonershave recived legal mai hat was opeacd uside of thei presnce orhave i outgoing gl mal opeped oiside f thic presence. Thes insancesare documented by the vitmized pisonrs by the Gl of ievancessnd occasonaly, th Kl of Section 1983’s. Thispractic ofopening Disoners” egal mail outid of hei rescnce i untica,immora,an illegal. See Barlow vs. Amiss, 477 F.2d 896, 895 (5* Cir. 1973); Taylor vs. Sterrett, 532 F.2d 462 (5* Cir. June 1, 1976; Frye vs. Henderson, 474 F 2d 1263 (5* Cir. 1973); and Criz vs. Hauk, 135 £.24 473 3ty Ci. 1979  ‘At i s ha been addressd several s the PCCOS cotine 1 oppress e prsoners witkin heir care by tampering with her incoming an ouigoing lgal mail outsid of i presene, This, s siatedsbove, s llegal. S Smith vs. Robbin, 454 F.2d696 (1" Cir. 1972).  T law speifically st thst el il can only be pened i A.) the s srong. videnc 10 suggest thatth concats are, infct, ot legal il and B.) the prisover that ‘e il s akdresed 0, o from, i pres. Sce IWolf vs. MeDonnel 418 US 539,945 i 2963, 41 L £ 24553 (1973,  The Constitaion parsntesth igh orprisoncrs 0 send outandrecive mai hatis contdental (egal mai. Thisllgaton s validted by the irs, Fourth, and Fourecah ‘Amendmensofthe Unitd Saies Constituton. Thisrigh is nonegoiable nd cannor < nfringed upon  “mendimeat 1 “Congres shall ke no law respecting a esablishment of relgion, or prbibiing e re excrcie thercof or sbrdging the Feedoms o specch, o of he prss, O he Fight ofte popleto prsceabi ssemble, and o petition the governmeotfora redres of revances "
Amendment &: “The right o the people to be secur in thir persons, houses and effects, sgainst unreasonable searhes and seiurcs, shall not b vigla warants stalissu, but po probablecaus, supporte by Oath of Affminatien g particulaly describing the plac t be sarched,and the person orhings o be sepe  mendment 14: Section 1) “Allpesons bom or naturalize in the Unitd St st ubject the jurisdicton theref, ae citzensof the Unitd States and the State wperr, they reside. No state shall make or enforce any law wi  shall abridge the privileges or mmunities o ciizens of the United Staes;nor sl any stae deprive any person o 1.  Hiberty,or propery, without due process of the aw: nor deny to any person withn s jurisdiction the equal protection of the laws.”  (Sestion 5) “The Congress shall havethe powes 0 cnforee, by sppropriat legisaion, the provisions of this aticle.”  Therefore, ifprson offcial open  prisonecrs legal mail then said prisoner has to be present when opencd as according to law. Scc IWashingion ve. James, 743 F: 34 1) @ cir. 1986).  Unfortunately, PCCOs ignore the law and maicinusly oppress theprisoncrs within their car.  Py !, and no  . ecourse, 15 at esort o ebellon agint ryranny and opprcsion, ththuma s  should be protected by the rle of the law." Indeed,in his speech entiled “The Perpetuation of Our Poitcal Institutons’ Abrahar Lincoln said, ..if the laws be continualy despscd and disrgarded, f het righe o secure in ther pesons and property, re held by no hette tenure than the capricn mob thealienaton of thei affections from the governmont i th raural consequence; ‘and o that sooner or lter, it must come.” ‘Therefore, PCCOS must uphold the law asisth prisoners’ legal mailor they are violating the Iaws prociaim 10 stand for as agents of Amerikkka,  duty and cease to tamper wigh ideas. and standards tha they  First & Fourteenth Amendments: Access to the Courts  “The First and Fourteenth Amendments guarantcesprisonerstherigh o access f the court. This includes, but i no imited to, adequate low Iibraris that re accensibe every prisoner.  Pontic Cormestional Center Offcals provide in-alequate law lirares (0 prisoners i segegaton sats. The egal books withinthe sgregation awibrry are tom up an otherwise defaced. See Bound vs. Smith, 430 U.S. 817, 975, Ct. 149] (v..the fundamental constitutonalright of access 0 the courts requires prison autharities assist inmates...by providing prisoners with adequate law libraries...)  The Constituional Right o access o the courts is s fundamental that the courty  eguire orprison ofcal 0 provide adoquae aw librarics o prisones. Sec Founger vy Gilmore, 404 US. 15, 92. CL. 250, 30L Fd. 2 142 Tip. 149401500,  Books Required 1o be Available in Law Librarics 1) Relevant state and federal statutes;  2) State and Federal law reporter from the pact few decades: 3. Shepards citations; and 4) Basic teatses on habeas cor  s, prisoners” civil rights, and criminal I,
Howeve, he books must s b uscabl. In Pontae Correctional Cente segregaion i the books ar ripped apart, missing pages, nd otherwise damaged. The g e quch condition becaus the priso officialsae delibersely indiffrent n the o not fllow the rosedure thy thenseves mplement. Sec PON 0348 Spcicaly,prisomoficials dono s prsoners bfoecnerin, e g e S T sseregaion. This sl nthe danaging of e legal boks.  A sotr e requird hat L s be of e size, S Sharge s e 24289 (7 Cir 1992 wnd Cepulois vs. Fir 132 F. 241 (1 Cr. 1894,  o brates with Pontiac Comectionsl Cener segregalion do ool me that e . They are the s iz hcls o which prisonrs eside. Indcd, i st el tha have beca convered into “law libeaies”  o (2) law s i Norh Cel House segrgtion. Each law ibrary e e, ay conains two (2)shelvesofbooks,and only e (1) prisonce s e given law braryatone tim. The law ibary canonly b used o0 3 st e Mt 500 P Satuday hiough Thusday. And tese small aw s e ncds of approxiniely four hudred prisoners st any given tme.  Neadless 0 53y, they ae inicequst  e el canno e vor i  prisonr’ ight 10 ccess o the couts. Sce o Gl 313 US. 346,61 S Ce 610,85 EL 1034 1941), el inking B ove th Law, Pontas Comectonal Cenir Offiials do abridge snd plr e igh s o he cours by poviding and maitiin sl madquate T librrics 1o prisoner wilhin segregation.  el have the iy o provide risoners with adequate lw libcaries Sce o e 405 U 319,321, 52 1 1075 1081, 31 L d 24263 (197, wd e Somchcombe, 412 US. 17, 34n.22.93 S Ci 1977, 1986, 36 L E4 24714  728(1973).  First & Fourteenth Amendments: Freedom of Religious Activity  e -Fre xcrsise Claue” of the Firs Aendnnt and e “Equal Proteion Clause” o P Amendment peoect 4 pisoner’ right 0 bave it inand xcris of Seligion withoutbeingdiscriminstd against due 0 ther bele  vt Amendment of th Urited Suics Consttution says inpar;“Congress shall otk o aw respectin an stablishmeat of eigion, o protibitig e fes exercse thereof..”  s hat s citzens ofthe Urited Statesof Amerika prisoners bave he igft o praiee religon ithout discrimination by priso auboris. As longas your belief s s and s prisonoffcsls canno mpede youfom pracicing . S Love 5 ‘Reed, 216 F. 3d 682 (8" Cir. 2002).  e e Comectonal Center Offcals obsisut prsoners o praciing Ui liious e housed in North Cel House scgregation and placed on One Galley. v e ight o et iha rligios eader and 10 annd eligious srvics of i faith  “About once a week cither the by ontiae Correctional Center or religious  A . o the community vl hrough he stnion and sop at pisoncrs” cels o  o alny of North Cel House. Thus,denying iyt prsooers o theif igh 0 e ilh eligious leaders cach time that the religious
Prison offcals cannot treat members of any relgious domination different than others, “This means that th fifty-two who reside on One Gallery of North Cell House are guaranteed by law to have the opportunity 1o meet with religious leaders tht the other e hundred risoers n North Cell Hous bave. Soe Gz vs. Bt 405 US. 319 ) (1972).  [n 2000, Congress passed the Religious Land Use and Insttutionalized Person Act (RLUIPA) which protected prisoners" right o pracice their religious belefs. RLUIPA tate tht aprison cannot *..impose a substantial burden on the religious exercise of a ‘person esiding i or confined 1o an intitution.” Sc Charles vs. Verhagen, ~F.3d—, No. 02-3572, 2003 WL 22455960 (7* Cir. Oct. 30, 2005).  However, by probibiting eligious tours of One Gllery in North Cell House, Pontiac: Corectional Center Offcials do exactly what RLUIPA prohibit; they impose a substantil burden on prisoners’ religious belcts.  ‘Their unethical and immoral - not to meation iliegal - behavior s not justified in any way, shape, or form. Only when essential 0 prison security and discipline can prison officias plac restricions on religious actvities. Sce Washington vs. Lee, 263 F. Supp. 327,331 (MD. Ala. 1966).  Being tha all of North Cell House is made up of prisoners who are in segregation status or administraive detention the exclusion of prisoners on One Gallry of North Cell House receiving relgious leaders is un-substantial and therefore cannot be deemed o5 s precaution towards institutiona securityor discpline. 1f prisoners on the other seven galleriesare allowed o meet with reigious leaders even though they are in segregation it only goes to show that prisoners on One Gallery should be afforded the same right,  e, that ’t the casc. Sadly, prisoners who are placed on One Gallery of North Cell House ae treated diffrcatly than those on the other galleies of North Cell House for no reasonable reason. This is a violaion of their right (0 equal protection as s forth i the Fouteenth Amendment.  “All ersons bom or naturalized in the United Stats...are citizens of the United States...No sate...shall abridge the prvileges...of citzens of the United States, nor shall any stte deprive any person of lfe, liberty, or property...nor deny any person. ..cqual protection of the laws." Fourtecnth Amendment of the United States Constitution.  Education  “The purpose of incarceration i rehabilitation of prisoners so that upon release from prison they can re-nter society as safe and productive citzens.  Rehabilitation consists of, but i mot imited to, cducational and vocational classes,  therapy, counseling, and Narcotics Anonymous (N.A.) and Alcohol Anonymous (A.A.).  Pontiac Corectional Center does not offe any of these rehabiltative programs to  prisoners i segregation.  “Thisis a direct violation of any prison’s mission; to rehablitate prisoners. Joan Petersila sid in the article “Beyond the Prison Bubble” that it should not come as a ‘suprise toleam that we bave a corrections sysiem that does not comrect™ Indeed, why should we expect our corrections system to correct when prison officials do not offer rehabilitaive programs o the vast majority of prisoners? Partiularly, Pontiac Corrctional Cener Offcials refuse o give prisoners i segregation any rehabiltative programs (o participat in.  ‘The Pontac Correctional Center Orientation Manual states on page 38 that prisoners in segrogation status will be given access 10 educational classes upon request;  “(F) Edveation: (1) Offenders confined in segregation status may submit a request for basic educalional materials. The Educational Faclity Administator (EFA) will review
N . The majority of vomen in prisun are cand use. Viomen bear the bruit o po failing to earn enaugh marey to sure chouse between staying out of 31 o  ©80% of vomen In prison report inc and 92 report incoines uider Sic  O Since 19k, 1  © 1979, et then bl o she for nonviolent crimes  Wiite collar crime drains $200 billion per year from the US econuimy,, is less than S5 billion, Finding a white collar criminal in most jisons, | who can afford high-priced lawyers and witnesses rarely do il i court appointed atlarneys who seldom have the time or resources Lo de  © The Savings & Loan frauds have cost US taxpayers at [  © The US now imprisons mare than Len times as many divg dealers and users. Al the same (ime more than S250 bilion i diug convictions for money laundering are fow and far betvicen.  135 il
et e property eiimes, such as checi forgery, check liting, and illegal credit s that criminalize poverty, being sert 10 jail and placed un probation for  . AL {lz sie time, the satety nef has been slashed, forcing many women to . \; din e Kids,  s of less than §2,000 per year [n the year befare their arrest,  Vison has increased by mpre than 275  aulin prisoi were there for nunjviolet ciinies. Togay, 70% are tivie  e the ecunanic cost of “stree} ctin bisever, would e no’smal task, Thuse & 1ose who can’t must make €4 vith  i i in 1980, most of them los-{eved ofits £ through US banks each year whili
the request along with the offender’s educational level. The basic education material appropriae o the educational level of the offender will be sent o the segregation unt for the offender’suse. All mateial will be in th form of workbooks or worksheets. The material will b retumed to the Educational Faciliy Aduministrator, evaluated and ‘additonal materials may be provided. 1z  “Note: Unlessspecifcally approved by the Office of Adult Education and Vocational Services nd the Facility Chief Administrative Offcer,offenders in segregation status il ot b eligibl to take the G.E.D. exam. No credit i given for mandate days or EGCC whil in segregation satus. No offender will be abe o take the TABE. Test™  Pontiac Correctional Center Officals do not allow offender insegregation statis o partake in any educationa classes. In allrality,prisoners are uoable 10 do 5o because of the prison offcal’s oppressive estictons tht thy themselves aciliated. “No offender will be able o take the TA B test”  “The T.ABLE. tesis th tet offenderstake o determine their educational level. By not allowing prisoners o take the test while n segregation status, Pontiac Correctional Officials effecively disqualify every prisonee within segregation from participating in cducationa classes.  S the above reference; “The Educational Faility Adrministstor._will eview...the offender’s educationa levl. “By prohibiting pisoners from taking the T.A B.E. test while in segregation staus the EFA is not able o review a requesting prisoner’s cducationallevel because a record of such does not exist. This results in the prisoner’s requestautomatically being denicd. This act is knowingly and willng commitid by Pontiac Comectional Center Offcials 2 asystematic mode of oppression which is perpetuated o that prisoners do not rehabilitate and therefore retum t0prison after release, Remember, more pisoners equals more money for prison officials whie less prisoner’s equals less money.  ‘These procedures re in violation of DR 40550 which can be located on pages 39-40 of the Pontiac Correctional Centr Orientation Mamual  “DRS04: Adult Basic Education Requirements for Offenders Commitid fo the Adult Division o or aferJanuary 1, 1987:"  (3 Offenders who are commited o the Adult Division of the Department of Correction on or afier January 1, 1987, fo two or more years, or who have been commitied as Sexually Dangeros Persons, except those offenders serving cither a lfe scatence or a death penaly senteace, will be given an achievement est within 20 days of ther arivalat the Pontiac Corrctional Center. Offenders whose composite sorc in reading and mathematics is below 6.0 (6" grade level) will b required to complete  90- Ay stcadance program in rading and mathematics. Any exceptions o this requirement must be made by both the Warden an the Suprinicndent of School District No. 28. Failure to comply with this requirement may result in disciplinary action and/or restriction of assignment pay.”  Obviously these two statements contadict each other, The irst sas, “No offender shal take the T.A B.E. test” While the secood says, “Offenders who ae commitied o the Adult Division of the Department of Corrections on o afer January 1, 1987....willbe given an achicvement test within 20 days of their arival a th Pontioc Correctional Center  However, the former is aregulation enforced by the PCCOs whil the late s the law. Inrefusing o allow prisoner’s in segregation 0 take the TA.B.E. es, thy are breaking the law; pure and simple. For the T.ABLE.test s the "achievement es” that i ‘mentioned in DR 405 50  “This means tha the Pontiac Corectional Center Offcials are ot lving up o their mission s aid out in the Pontiac Correctional Center Orieniation Manua to rehabiltate the prisoncr’s under their auspices.
Due 10 thei tyrannical behavior the prisoner’s o Pontiac Correctional Center whoin segregation are denicd cducational, and therefore rehabiltative programs. This resuls in the degeneraton ofprisoner’s psyche and well-beng which culminates in  high recidivism rae amongst prisoners. 3  Eighth Amendment: Proteciion From Physical Brutality  “The Eighth Anmendment protctsprisoners from physical brtality undec the “Cruel and Unusual Puishment” tandards. Thisincludes excessive force by guards within prisons. See Hudson vs. MeMillan, 503 US. 1 (1993).  Employees at Pontiac Correctional Center know as Correctional Officers have a repettive and violent history of brutally assaulting prisoncrs. Many prisoners have becn viciously artacked by PCCOs because they have flooded teir cll, assaulied staff, popped sprinklers, and used explicit language towards staff, Mosi of the tme prisoners do these things as s means of proteting their oppressive treament.  ‘The comectional officers of PCC have perfected a method of being able 1 safely beat prisoncrs. First thy group together. Next they handcu and shackle the prisoner. And then they attack him.  In Hudson vs. ke Millan, the Supreme Court found tha a prison guard’s use offorce is unconstituional when it i not spplicd “...n a good fath effot to maintain of restore discipline” but s instead used to “malicously and sadisticaly cause harm.”  ‘When someone is considering whether the force used s excessive or o, you would have 1o considerte following:  1) The need for force.  2) Whether the amoun of force used was reasonable given the need. 3) How serious the need for force appeared to the guards.  4) Whether the guards made efforts t use as lte force s nccessary. 5) How badly you were hurt.  Using e method prefrre by the correciiona offcrs of Pontiac Correctional Center, 1 il now address ach of thos questions n ordes 0 demansuae the physical abuse prsonersface by the hands of their guardians.  1) There i 0o need or fore if a prisones is aready consirained by handeuffs and shackls. He poses o isk 10 anyone and he corectonal oficer’s ssault of is person ‘while he is consiraned by eanacles is unconsttutional and llegal.  2) As noted bove, her i o justficaton or the use offoee by comectional offcers agansta prisoner who i bound by handcuffsand shackles i Defenselss).  3 The guards canno resonable proclai that ey belived ay force was necessary ‘when the forc n quetion was used agansta prisoner that was already resrsined.  4) As noted above inthe answer o No. 3, i a prisoneri bound by handcuffs i shackis there cannotbe any reasonable excuse for using force aganst him. Thercfore, any force that s sed i b considered as excessiv and cano be considered s the use of“as e foce as necessary” because none was necessary!  “Therfore, e cousiderin th responses o hose five questions it s extremely casy o s hat prisones of Pontac Correctional Cente ae being savagely attacked by the cortctonal officers whose job and duty i i o protectand care for then. Such behavior isllegal and humane. e Wilkin vs. Gaddy, 130.Ct. 1175 (2010); and Wiliams v Jackson, 600 F. 3d 1007 (8* Cir. 2010).
Eighth Amendment: Right 1o Decent Conditons in Prison  “The Eighth Amendrment’ probibiton of crcland unusual pnishmentalso protets a pisoner’s ight o safc and somewhat decent conitonsinpriso. Sce Rhodes v hapman, 452 US 377, 345.46 1015 CL 2392, 2398.99.69 L £d 2459 (1980). |  Sanitation:  Pontiac Correctonal Center Offcals knowingly and willingly foce prisoners tolive in unsanitary conditions that are often dangerous to one’s health. What makes this even ‘more outrageous i the fact tha they could fx this problem if they wanted to. They don’t. The PCCOs are puting prisoners’ danger with despicabl discases that have the potential of being deadly andlor contagious (. Hepatits C, Staff Ifections, Pocumenia, etc... This deliberste uncaring negligence is inhumane and illegal. See Helling vs. McKinney, 509 ULS. 25 (1993).  Each cellwithin North Cell Fouse is equipped with a ven 5o that air can be circulated hroughout the cell. However, these vents are never cleancd o they have accumulaied a Significant amout of dust,lnt, and debris which makes them nonfunctionsl. Because of al of the accumulated junk inthe vents the PCCOS are forced o keep them fumed off. “This means two things - 1.)ai i the cell s not circulated; and 2. th prisoners can (and sometimes do) suffe severe harm. See Gibbs vs. Cross, 150 F. 3d 962 (3" Cir. 198)  Prisopers are etitled to sanitary living conditions. See DeSpain vs. Uphoff, 260 F. 3d 965 (10" Cir. 2001); Martino vs. Carey, 563 F. Supp. 984, 1001 (D. Or. 1983); and Ruiz ve Estelle, 503 F. Supp. 1265 (1980).  “Thisincludes the ight to have adequate cleaning sup  Once a week on Sundays PCCOSs issuc ane half cup of diluted disinfectant soap o each prisoner. This halfcup i expected to work miracles. Firs, it is supposed 1o last a Prisoner until the following Sunday. Secondly, it s supposed to be enough to properly clean the walls, i . tolet, floor, door, chuck-hole, sk, and bed of the prisoner’ cel. Obviously hisis not enough disinfectant o meet those ulopien expectaions.  1t would b quite simpl for PCCOs o give prisoners more disinfectant soap per week. i cold be done one of two ways. 1, It could be tha they give prisoners a full cup every Sunday; o 2.) They could give out onc half cup wice every week. Unfortunately, they refus o docitherand force prisonersto liv in flthy environments  Ponti Correctional Center segregation houses those prisoners who have violated institutional rles and ar being disciplined with solation. It is necdless to say that some. of theseprsoners are mentally ll. These mentally il prsoners ae actally supposed to be housed separately from the “sane” prisoners ~ they’re not  “When a prisoner throws urineor feces onto the gallery (he walkway outside o the cells) PCCOs leave it there and refuse o clean it up. The only time you wil s them clean up the wastc i if cither the Werden or the Director of IDOC i about o tourthe cell house.  S0, unless their bosses are coming through for an inspeciion, the only means of having the wast cleancd upis on 1* shift when the medium-security prisoners tha act a5 janitors are n thecell house. This means tha if any wasteis thrown ono the gllery on 2% or % shift it wil emain there unilthe following day when the medium-security prisoners come back in on 17 shift  Therefore, risoners have to put up with the smell toxic fumes, and insccts that co-exist with such filth. Typically, when addressed about this problem PCCOs say “I’m not cleaning it up. Wait unti day shift.”
Naurally one woud say, “Don’t throw wast on the gallery.” And fyou saythat you arecomect. Howerer, there i no possible way for prisoners 1 preven ober prisoners from doing s0. We are in our cells twenty-four hours a day. Is  By forcingpisoners 1o lveinsuch it conditons the PCCOs e subjcting the prisoners undertheir cae 1 cracl and unusual punishment. See Trop vs. Dulles, 356 US. 86, 101, 785 Cu. 390,598, 2 Ed 24 630 (1958); 30d Spain vs. Procunier, 600 F. 2d 0  These condiionsar unhealtky, inhumane, and dangerous. They can esut in scrious sicknessand even deah. Prison officials have the responsibiliy (o et prisoners i safe and sanitary envionment. See Coldman vs. Schwarzenegger, 2009 WL 2430520 (ED. Cal): 30 Farmer s Brennan, 511 US. 825, 114. Ci. 1970 (1994).  .. prison offical may be held iable under the Eighth Amendment for denying. utmane conditons..only i thy know tha inmate face substantial ik ofseious barm nd disregard that ik by ilng o (ak reasonable measures o abate i...” Farmer s Bremnan.  Poutiac Conctional Center Oficialsarc aware ofthe sanitation violaions with PCC and hey do pothing 1 abae those violtins.  Prsoners are also supposed 1 be given proper grooming supplis. Indeed,a prsoner is expected o keep imself wel groomeed atallimes. See DR 502.100  However, this is not possibe due 1o PCCOS” alire t0 comply withinstitutional rules. Page 23 of e Poniae Correctional Center Orieniation Marual saes tha prsoner e lowed 1o have combs so it they can keep themselves groomed and presentabl. Yet, PCCOS do ot band out fee combs 1o prisooers pon ther vl nordothey sellcombs ou the commissary. See De 7861  Any prisoner who i nor wel groomed at all s will be ssucd a DOC 0317 Disciplinary Report. Sce Page 35 (4) of the PCCOM.  “The commissary sell ony a palm brush wich ismade ofcheap,fisy plasti. This meas that Afikan- Amerikkkan prisoners cannot mainain thei grooming because the palm brush breaksintheircurly, nappy hair. Inorder t0 keep her appearance. prescotabl hey need a ommb o  bair pick  "Alo,the commisary does not el prisoners insegregacion saus dentl 105 o s srease. Hair greae s necessacy for Afrkan-Amerikkkan prisoners o keep their scalp om drying out and peeling.  Without dental flos tatar ad plague build up around the guums i placestht  ooth brush cannot reach. Thisresuts in bad breath,Foting teth, and gum discase. There is o penological nterest” i denying prisoners i segregation combs, reas, o dental foss. The denil of such s a acic that PCCOS use 0 0ppress prisoners.  Lighting:  On One Galley of North Cel House all of thecells are Lt twenty-four bours a day. “This cuses sensory deprivation from being,exposed to light constantly without reprieve  Sce LeMaire vs. Maass, 745 F. Supp. 623 (1990).  “This means that at all peiods of the day ffty-two prisoners in North Cell House are being systemaicallytortured by excessive exposurs o light Placing prisoners in  cell tha s constantly it has the same effect as placing them in cels that are constanly dark. ...here is no evideoce tha...saff neds o see nto the...cels for 24 hours per day, or thal they are even nearthe...cels for 24 hours per day. Defendant offered no reason the clls could not bave switches outside so guards can see nto them when they must LeMaire vs. Maass.
Instead of turning a light on, or using a fashlight to seeinto acell when necessary the ’PCCOs maintain 8 constant llumination of the cels on One Gallery of North Cel Hlouse “Thereis no penological interest fo requiring plaintiff 1o suffr physical and psychological harm by living in constant llumination. This practce is unconstituional.” LeMaire vs. Moass.  Fourteenth Amendment: Du Process A  “The state shall not deprive “any person of if liberty, o property without due process of the law.” This is known as the "Due Process Clause" of the Fourteenth Amendment. ‘When prison offcial violate tis right a risoner has a “liberty interest” See Wolf vs. McDormell, 418 USS. $39 (1974); and Sandin vs. Connor, 515 US. 472 (1995).  Meal Loaf:  ‘Whenevera prisoner of PCC segregation assaults another prisoncr ora guard the prison offcals lace him on Meal Loaf status without the due proces ofa disiplinay hearing. Before the prisoner is ound guily of the assaulthe s accused of commi punished with Meal Loaf. If, after his committng the assault he illegal. See Fifh Amendment  "Meal Loafis the lelover scrap of any mesl tht re first grind up and them compacied {ogether and baked nto  brick. Prisonersare placed on Meal Loaffora mimimum of thee days  I the past the courts have declared that Meal Loaf i, in el constituional. See United States vs Michigan. 680 F. Supp. At 275: and Smith vs. Oregan State Dept.of Correction, 101 Or. App. 539, 792 P. 2 109 (1990).  However, when Meal Loaf is used s a punishment for anything not o do with the abuse offood or cating wensils it is unconstittional. Sec ZeMaire vs. Maass, 745 F Supp. 623 (1990)  In LeMaire the court concluded that Meal Loaf s purishment s iegal. “T conclude that theuse of Nutra Loaf a punishment violates plaintif"’s Eighth and Fourteenth Amendments ights.™  The court ound a similasrling in Moss vs. Ward, 450 F. Supp. 591, 596 (WDN.Y. 1978). . prison offcials cannot impose such severe sanctions for breaking disciplinary ule..when ther is o showing tha the prisoner is cngaging in the condut the ule designed o provent.”™  See also Finney vs. Arkansas Board of Corrections, 505 F. 2d 194, 207-08 (8* Cir. 1974): and Finney vs. Hutto, 410 F. Supp. 251, 276 (E.D. Ark. 1976).  Onlyifa prisoner abuses his food orexting uteusils can he be placed on Meal Loaf Assauling otberprisoners or guards is ot punishable by Meal Loaf. The court also decided in Lemaire that feces and urine do ot constite the same 55 food. I prisoner does throw urine or feces (as disgustingas thatis) be cannot be placed on Meal Loaf.  Pontiac Correctional Center Officials usc Meal Loaf as a purishment for several things (. assultng sa, disespecting stff trowing feces andor uine, cc...)  Bt back t duc process - placing pisoners on Meal Loaf prior o being found uilty at a disciplinary heariog violates the prisoner’srightto due process. In Wolffvs. McDonnell the court cleary declared that prisoner have therigh t a disciplinary hering beforc being punished for an alleged rue infaction.
Strip-Out: 7  Pontiac Conectional Cenier Officials have  tendency of sipping out (iking away all  of ther property) or various rule infractons but they do so unconsttutionaly for two (2) Firs, the Segregation Procedure Manal, which s published by the Department of  Corections,sys o page 7 hat  prisoncecan ol b sriped out fo te following:  1) Helights a fire in is cel. 2) He floods his cell 3) He hams himself. 4) He hams somebody else 5 He damages or misuscs staie propery.  Pontise Coretional Center Officals strip out prisoner for reasons oher than the five: listed above. 1fa prisoner i being loud or is found possessing any contraband he will be sripped out.  In LeMaire the ourt found that the use of scip-out tatus for anything other than the abuse of property s unconstiutional. Therefore, not oaly s it unconstinutional to strip- ot a prisoner for being loud or possessing contraband, it s also unconsttutional to strip- out a prisoner for any of the first four reasons lsted on page 7 of the Segregation Procedure Manual.See Wright vs. Rushen, 672 F. 24 t 1133; and Estelle vs. Gamble, 129U, a1 103,97 e a1 290.  Secondly, PCCOS do notallow prisoner 10 prove ther innocence of alleged rule infractions before stripping them out. This practic is unconstitutionel.  Disciplinary bearings exist 5o thatan offender can prove his innocence before being. ‘punished for something he may in fact not be guilty of. Stripping a pisoner out before. he is found guily at  disciplinary hearing i the equivalent of exccuting someone. withouta tial o determine their guiltor innocence  Prisoners have the right o prepare a defense before their disciplinary hearing. However,due tothe fact that prisoners are strpped out for 8 minimum of seventy-two hours it makes it extremely difficult - if not impossible — 0 do so.  In ssence, PCCOs are in violation of the law as pursuant to LeMaire in regards to using strip-oul satus a5 a punishment for anything other than the abuse of propentylclothing and preventing prisoners fom preparing  proper defense at their disciplinary hearings by stripping them out before they are found guily.  Conclusion  “Thisreport s been prepared not o shed light on only one injustice perpetuated by Pontisc Correctional Center Officals but 0 show a wide spectrum of cveats commiticd by said officials of Pontiac Correctional Center that are oppressive o the prisoners. ‘confined within saidinstituton.  “These multipl infractions of the United States Constituton have resulted in severe ‘physical and psychological harm 1o the prisoners detained within Pontiac Correctional Center. Very recenty it was found that such conditions are unconstitutional and herefore llegal. See Coleman vs. Schwarzenegger, 2009 WL 2430820 (E.D. Cal).
Injunctive Relief N4  In Tightof the information provided throughout tis report o the oppression of within Pontiac Correctional Ceater it is demanded by — not the author o prisonersof Pontiac Correctional Center individually ~ humanity as a whole tht these oppressive acions be remedied through the following.  1) Thatthe Pontss Corretional Center Offcials stop theilicgal banning of publiations hat have o penological interest o the intitution and tht the kecping of alst of banned. jeations be ceased due to the legality of such a list. 2 That the legalopening of prisoners*Jgal mail outsideof ther presence be stopped enmedintelyand any prison officialfound guilty of iegall opening legal mail be severely puished. ) That te law librares be enlarged and that prison officials ollow guidelnes to prevent the daraging of egal books. Also, that all damaged legal books be replaced. > That Poniac Corctional Center Offcials allow prison=rs confined on One Gallery of North Cel House o meet with eligious leaders asthee i no penological interest n denying them ths right. 5 "That pon arival at Pontiac Correctional Center all prsoners senenced o two o ‘more years - exceptthose serving e or death penalty seatences - b given the TAB.E. st within 20 days and that prisoners in segregation status b allowed to partcipate n cducational clases 16 That the habitual use of excessive force against prisone: by Poutiac Corectional Center Correctional Officers be put 0. stop. That camers’s be placed on every gal and in every staiwell 1 belp prevent the use of excessive force. And that rison off found gty of sing excessive force against prisoners be severely punished. 7y That prsoners be issved mre than a haf cup o disinfectant soap per week. Eiher by ssuing ooe fllcup every Sunday orisuing two halfcups o prisonersevery week. “Thatthe veats b periodically cleaned. That the cleaning of any and all bodily luids and wastes be done prompily and efficienty. And tht prisoner’s be llowed to purchase Combs, grease,and dentl loss off ofthecomissary. And that the cel on One Gallery of North Cell House nor be lluminated twenty-four hours et day. 8 Thatthe use of Meal Loaf s a punishment for anything othe thanthe abuse of food o cating wtensilsbe stopped. That the pratice of placing prisoners on Meal Loaf before. they are found gty of busing teir food and eating utensils be stopped. Thatthe use of irip-ou staus 4 a punishment for anything otherthan th abuse of property and clothing be stopped. And that the praciceof placig,prisoners o sirip-out status before they are found guily of abusing their property and clothing be put >3 stop.  s a collective whole of civilized humasity it is demanded that vry one of tese  remedies be met - with NO xceptions! To not abnegate o these demands s to alicnate oneself from the civilized world and into a barbaric ightmare. - For prisoners are humans and therefore they have rights.
3) 34)  35) 36) 37)  38) 39) 0y 41) a2) a)  References 9  Tumer vs. Saley, 482 US. 78 (1987)  Thomburgh v. Abbott, 490 U.S 401, 404 (1989)  Willams v. Brimeyer, 116 F. 34 351 (8* Cir. 1997)  DR 525210(s)  Departmental Kule 504.209 Dangerous Writien Material Department Rule 504.308 Contraband or Unauthorized Property Departmental Rule 504310 Abuse of Prvileges  Departmental Ruke 504.403 Disobeying a Direct Order Departmental Rule 504.404 Violaton of Rules  ’DOC 0317 Disciplinary Report  Gates vs. Coller, 501 F. 24 1291 (* ir. Sept. 20, 1974) Procunir vs. Maninez, 416 U.S. 396 (1974)  Bach vs. Peopl of the Stat of lnois, 504 F. 24 1100 (7 Cir. 1974) Adams vs. Carson, 488 F. 24 619 (7* Cir. (1973)  Moore vs.Ciccane, 8® Cir. 1972, 459 F. 24 574  McCray vs. Sullivan, $® Cir. 1975, 509 F. 24 1332  Pontac Correcional Center Orieuation Manual pg. 17  Castillo vs. Cook County Mail Room, 990 F. 24 304 (7* Cir. 1993) Bacdow vs. Amiss, 477 . 24 89,898 (5° Cie:1973)  Taylorvs. Seret, 532 F. 24 462 (5° Cir June 1, 1976)  Frye vs. Henderson, 474 F. 2d 1263 (5* Cir. 1973)  Cruz vs. Hauk, 475 F.2d 475 (5" Cir. 1973)  Smith vs. Robbins, 454 F.2d 696 (1 Cis 1972)  ‘Wolff vs. McDonell, 418 U.S. 539, 945. Ct. 2963, 41L. E4. 24 935 574  ‘Washington vs. James, 782 F. 2d 1134 (2 Cir. 1986)  “The Perpetuation of Our Pliical nstitutions” by Abraham Lincoln Bounds vs. Smith, 430 U.S. 817, 975. Ct 1491  Younger vs. Gilmore, 404 US. 15, 925, Ct. 250, 30L. E4. 24 142 Pp1494-1500  Pon 0348  Sthango vs. Jurich, 965 F. 24289 (7* Cir. 1992)  ‘Cepulons vs. Fair, 732 F. 24 | (1 Cr. 1984)  Expure Hull, 312 USS. 546,61 5. Ct 640, 85L. E4. 1034 (1941) Cruz v. Beo, 405 US. 319,321, 92 5. CL 1079, 1081, 31 L. Ed 24 263 )  Chuffinvs. Styncheombe, 412 US. 17 340. 22,93 5. 1977, 1986, 36 L E424714, 728 1973  Love vs. Reed, 216 F. 3d 682 (8 Cir 2002)  Religious Lund Use and Insitutonalized Persons Act  Charles vs. Verhagen, - F.3d -, No. 23572, 3003 WL. 22455960 (7" Cir 0ct30,2003)  Washington vs. Lee, 263 F Supp. 27, 331 (M.D. Ala 1966)  yond the Bubble” by Joan Petrsilia  Pontiac Corectional Center Orieatation Manual pg. 38  DR 405.50  Pontiac Correctionsl Center Orieatation Manial pp. 3940  Hodson vs. MeMillan, 503 US. 1 (1992)
44)  Wilkins vs. Gaddy, 130, C1. 1175 Q0100  45)  Willamsvs. Jockson, 600 F. 34 1007 (8" Cis 2010)  46)  Rhodes vs. Chapman, 452 US. 337, 34546, 101 5. C1. 2392, 2398.99, 69 L Ed. 24 59 (1980)  47)  Helling vs. McKinney, S09 US. 25 (1993)  48)  Gibbs va.Cross, 160°F 34962 G Cir 1998)  49) DeSpin vs. UphofT, 264 34965 (10% Cir 2001)  50) Martino va. Carey, 563 F. Supp. 984, 1001 (D. Or. 1983)  51)  Ruiz vs. Estlle, S03 F. Supp. 1265 (1980)  52) Tropva. Dulles 356 USS. 86, 101, 78S, CL. 590, 598, 2 L Ed 24 630 (1958)  53)  Spain vs. Procunie, 600 F. 24 t 200  54)  Coleman vs. Schwarzencgger, 2009 WL, 2430820 (ED, Cal)  55) Fammer vs. Breanan, 511 US. 825, 1145, CL 1970 1994)  56) DR502100  57)  Pontiac Correctional Center Orientation Manual pg. 23  58) DCT861  59)  Pontiac Corrctional Center Orentation Manul g 15  60)  LeMaire vs. Maass, 745 F. Supp. 623 (1990)  61) Sendinvs. Conner, 515 US. 472 (1995)  62)  Fifth Amendment  63)  Urited States vs. Michigan, 680 F. Supp.at 275  64) Smith vs. Oregon Sate Dept. of Correction, 101 Or. App. 539,792 . 24 . 109 1990)  65) Moss vs. Ward, 45OF. Supp. 591, 596 (WDN.Y 1978)  66 Finney vs. Arkansas Board of Corrections, 05 F 24 194, 207-08 (8 Cir 1978)  67)  Finney va. Hutto, 410 . Supp 251, 256 (ELD. Ark. 1976)  8)  Segrogaion Procedure Maul pg. 7  69)  Wright vs. Rushen, 642 F 24 a 1133  70)  Esille v, Gamble, 429 US. at 103,97 5. CL a1 290  About the Author  Matthew Smith is a 20 year old political prisoner confined within Pontiac Correctional Center segregation. He is a communist revolutionary and is the leader and founder of the Political Party | $.0.B. (Soldiers of Bondage). Anyone who wishes to contact him  may do so at the following address:  Matthew Smith B86629 Pontiac Correctional Center P.0.Box 99 Pontiac, IL 61764
A Report on the Oppression of the
Political Prisoners within
Pontiac Correctional Center
2012

Written by:
Matthew Smith
(on behalf of 8.0.B.)
Contents
Introduction
Whatis S.0.8.2
Fiest Amendment: Access to Reading Maerial
First Amendment: Censorship of Mail
First & Fourteenth Amendinents: Access to Courts
First & Fourteenth Amendments: Freedom of Religious Activity
Education
Eighth Amendment: Protection From Physical Brutality

Eighth Amendmier

: Right to Decent Conditions in Prison
Sanitation
Lighting
Fouricenth Amendment: Du¢ Process
Meatloaf
Suip-Out
Conclusion
Injunctive Reliet
References

About the Author

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Edited by Anthony Rayson on November Léth; 2013

Published & Distributed By:

South Chicago ABC Zine Distro | POB 721/ Homewood, IL 60430
@nticopyright - free to prisoners - Each One, Teach One
Tntroduction 2

This report was written to shed light on the oppression of the politcal prisoners within
Pontiac Correctional Center. This oppression is perpetuated knowingly, willngly, and
continuously by the Pontiac Correctional Center Officials whose job and duy is (0 house.
care, and rehabiliate prisoners.

It the hope of the author tha this report wil open the eves of saiety 1o the inhumane
conditions and treatment of prisoners - speificaly those who are confined in Pontiac
Correctional Center. Purthermore,the author hopes that after their eyes have been
opened socicty will nite and demand that these oppressive actions be stopped.

‘Altbough prisonersare incarcerated for vaious crimes they stil have righs. Rights
that are being violated and ignored hy Pontiac Correctional Center Offcials. Hopefully.
with the hlp of the masses, that will soon end.

Whotis SO.R?

“The Soldirs of Bondage (5.0.8.) s a communist revoluionary politial movement
that i against Imperial Capitalism in all of it forms.

“This report contains ways that the current capitalist system oppresses the people of
Amerikka. However, it i by no means every way tha the people are oppressed.

5.0.B.i ot a gang nor does it advocate gang activity. Instead, $.0.5. educates the
‘masses about their oppression and advocates peaceable resistance (such as the
‘onstruction of this report). The movement was founded by Matthew Smith on July 2,
2011 within Pontine Correctional Center Segregation. The goals of §.0.B. are as
follows;
1.) To end the opression of the peaple perpetuated by the Amerikkkan govemment:
2) To end capialism; and
3 To implement communism into the government,

Again, S.0.B.s not a gang! 5.0.B. does not ndvoeate violence (armed-resistance) but
peace (passive-resstance). It s the i of §.00.. t counter oppression with iberation
and true-equality for all!

First Amendment: Accs 0 Reading Material

The First Amendment protects a prisoner'sright o obiain and possess reading material
Prison offcials cannot ban any publication unless they can show “legiimate govermment
interest” in prohibiting the material. See Turner vs. Safley, 482U.5. 78 (1978): wnd
Thornburgh. Abbot, 490 U.S. 401, 404 (1989).

However, just because prison officials have theright o ban publications that does not
‘mean tha they can abuse thatauthority. An example of Pontiac Correctional Center
Officials abuse of discretion s the construction and maintenance of st of publications
thathave been prokibited by said official.

A prison cannot maintain a st of excluded publications or decide that no materials
from a paticular organization willbe allowe . It must decide about each book o
‘magazine on n case-by-case-basis. This holds true cven for books and magazines that
prison offcils know have been banncd in the past. Sec Williams ve. Brimeyer, 116 F. 3d
351(8* Cir. 1997); and DR 525.210(a).

Prison offcils cunnol ensor nterial just begause it contains eligious, philosophucal,
poliical, socia,sexual, or unpopulas o repugrant content. They can only censor
moterial i they belive i willincite disonde or violence, o it will huta prisoner’s ¢

rehubiltation.” Thornburgh vs. Abboit.
Yet, even though the law gives prisoners reasonble protection, Pontiae Correctional
Center Oficials knowingly, willngly, and continuously infrnge on prisoners’ rights.
The probibition of Machiavelli, Robent Greene, Sun T, Clausewitz, ec... are in
Violaton of the procedures set forth in Turner. Turner asks four (4) questions of the
prison offcials banuing of publications. They are as follows;

e 10 8 legiimate, neutal govermment interest?
sother way for you 10 exercisc your

1) Isthe regulation reasonably rc

2) Does the regulation leave o
Consitutonal Rights?

3.) How does the regulaion impuct other prisoners, pison guards or offcils and

prison resources?
4 Are there obvious, casy altemalives o the regulation that would not restict your

righto free expression”

1 egands o the suthorspreviously menionca 1 will now respond 0 ach ofthe Turer
questons in ull.

1) The baaning of Machiavelli, Grecuc, Teu, and Clausewitz ae not related o any
legitimate, neutral government inteest. Pontiac Correctional Ceater Officials claims that
the material writien by them is “sccuriy threat” 10 he institution; but they do not

fy how they are threat
son officialscan *...censor material i they believe it willinite disorder ot violence,

or will hurta prisoner’s rehabilitation.™ Thornburgh vs. Abbort. - Emphasis mine.
throughout.

None of these authors advocate violence or Jisorder. They are historians and/or
philosophers who ponder many things such ss life, war, ove, success, and sociey. They
o not encouruge people 1o bar armis against the governmen noe do they suggest that
violence s the answer o society's problems.

They do not incte disorder, violence, or bur a pisoner’s rehabilitation. Thus, Pontiac
Corrctionsl Center Officials fl the first Tumer Question.

2. The bansing of Machisvell, Greene, Tzu, and Clausewitz does notleave open
‘another way for prisoners to obtain matcral witin by them and therefore prisoners
cannon excreis their Consitutional Rights 1 have access (0 reading materialas set forth
inthe First Amendment.

Being tha their works have been probibited prisoncrs cannot receive copics of them in
any way. Prisoners cannot have family and frends print matecial of o the intemet and
Sent o them because that would be a violation of Department Rules 504 209 Dangerous
Written Material; 504,308 Contraband or Unauthorized Property; 504.310 Abuse of
Privileges: S04.403 Disobeying a Direct Order; and 504.404 Violation of Ruls.

“These violations would resultin a Do 0317 Disciplinary Reportbeing witien which
would resultin loss of privilegs, loss of good time, demotion of grade, and segregation
time.

“Therefore,the bunning of said authors docs not allow prisoners o obtain thir works by
other means bocause their material has becn banned in i's entisey. Thus, Potiac
Correctional Ceater Official fal the sccond Tumer Question as well
3) The baning of Machinvell, Greene, Tz, and Clauscwitz et ll prsoners
because it preveats them from pursuing an cducation in cerainareas. 12 prisoner
wished 10 obtain a degree in poltical science he would be unable 0 do 5o because he
‘would inevitably come across such theorisftopics s war, society, strategy, taiics, and
revolution which are the main topcs wrtten bout by the above authors who have been
banoed.

Imagine. A prisoner pays for a correspondence cours in poliical science and as part
of hislesson must read Clausewitz, Tzu, Machiaveli, o Greene. He would be unabie to
do 50 due 0 the baning of them and that would obstructhim from finishing and
obtaining his degre.

“The baning of Machiaveli, Green, Tz, and Clauscwitz does not impact prison
guards, offcials, o prison resources in any way. Whether or not pisoner reads their
work the prison willconinue fo funcion safel and successfuly hecause ther matrial
does not advoeate disorde, violeace, or harm a prisoner’ rehabiliaion.

‘Therefore, th prohibition o these authors i nothing mor than an abuse of power and
way of oppresing prisoners within Pontioc Correctional Center. Thus, Pontinc
Correctionl Ceater Officials failth third Tumer Question also

4) Yes. There i an easy, obvious altemative (o the banning of Machiavelli, Greene,
Tzu, and Clausewitz. Pontiac Corrctional Center Officials ban all works refated to war,
sratgy, tactic, and revolution.

‘The altemative (0 this i 0 allow in books and magazines that discuss the theory of
these topics and 0 ban those that advocate the use of them. There is a mass difference.
between discussing the theory or history of war and discussing the desire to start a war.

However, Pontiac Correctional Center Officials refuse to iz this altemative and
‘contnue to sbuse thei authority and oppress the prisoners withn thei care. Ths,
Poniac Correctional Center Offcial il the fourth, and final, Turmer Question as well

As dictated ahove, Pontiac Correctional Center Officials
“Tumer Questions satisfactorily.

Machiavelli, Greene, Tz, and Clauscwitz are not the only authors victimized by
Pontinc Correctional Officials abuse of power. [ have used them only as examples of this
oppression and acknowledge tha they are only a fev of the authors who are banned
illgally.

to meet any of the four (4)

First Amendment: Censorship of Mail

“The First Amendment protects prisoners” right 0 send and eceiv letters. Generaly
prson oficials have the authority (0 censor incoming and outgoing mal for the sake of
sccurity. However, his does not petain o lgal mail which is (o remain confdential
See Gates v. Collier, 301 F.2d 1291 (5 Cr. Sept. 20, 1974): and Procumier v
Martine, 416 US. 396 (1979)

“The court decided n Collier tha legal mail consistsof any mail addressd 10 or rom
) All Federal Offiials including the President o the United Stics, any sentor or
‘congressman, and officils of any Urited States ageney or department;l state officials
includingthe Governor, membersof the sate Sene nd House of Representatves, and
officals of any satc agency or department.™
Pouic Comectional Center Officals bave & repetive istory of tumpering with
prisoncrs” incoming ad ougoing leal mail. This Ganpering obsircts a prisoner’s right
10 have aceess o the courtsund non-censored legal mail. Sec Bach vs. People o the
Suate of linois, 504 F. 2d 1100 (7* Cir. 1974); and Adams vs. Carlson, 488F. 2d 619
(7 Cir. 1973).

In Bach the court sid, “We think dat contact with an atorney and the opportunity (o
communicat privatly is vital ingredicnt o the ffecive assistance o counsel aod
access 1 the courts” See also Moore vs. Ciccone, 8 Cir. 1972, 459 F.2d ST4; and
McCray vs. Sullivan, 5™ Cir. 1975, 509 F.2d 1332.

Indeed, in MeCray the cout found that .. inmate’s right of unfetered aceess (0 the
courts i a fundamental a ightas any other he may bold... Al othe rights ae lusory
without it

O page 17.0fthe Pontia Correcional Certer Oreniation Marual it st n scion
) Ml Service:

Offenders may reive s ulinted b of s from anyone except a offnder
in snothe insitadon. s case, permisson ust b ganied by both failics wardas.
i will b openc snd cxamined fo conrabund, eccpt legal il which will be
apened by th officr delveingthe sl infront fthe ffnder, ad examined for
Contraband. The offende is requird 0sig sl satingthe ol was unopeaed il
the officer openod it i his presence. — Emphisis mie troughout.

i saepent s in ccordance 10 law. Sec Castill v, Cook Courty Mail Room, 990
F2d304 (P Cir. 1999)

However, even though these regulons e within th rle book,the ffcals of
Poniac Coretional Centerdo ot alvays comply it hen

There are severl instances when prisonershave recived legal mai hat was opeacd
uside of thei presnce orhave i outgoing gl mal opeped oiside f thic
presence. Thes insancesare documented by the vitmized pisonrs by the Gl of
ievancessnd occasonaly, th Kl of Section 1983's. Thispractic ofopening
Disoners” egal mail outid of hei rescnce i untica,immora,an illegal. See
Barlow vs. Amiss, 477 F.2d 896, 895 (5* Cir. 1973); Taylor vs. Sterrett, 532 F.2d 462
(5* Cir. June 1, 1976; Frye vs. Henderson, 474 F 2d 1263 (5* Cir. 1973); and Criz vs.
Hauk, 135 £.24 473 3ty Ci. 1979

‘At i s ha been addressd several s the PCCOS cotine 1 oppress
e prsoners witkin heir care by tampering with her incoming an ouigoing lgal mail
outsid of i presene, This, s siatedsbove, s llegal. S Smith vs. Robbin, 454
F.2d696 (1" Cir. 1972).

T law speifically st thst el il can only be pened i A.) the s srong.
videnc 10 suggest thatth concats are, infct, ot legal il and B.) the prisover that
‘e il s akdresed 0, o from, i pres. Sce IWolf vs. MeDonnel 418 US 539,945
i 2963, 41 L £ 24553 (1973,

The Constitaion parsntesth igh orprisoncrs 0 send outandrecive mai hatis
contdental (egal mai. Thisllgaton s validted by the irs, Fourth, and Fourecah
‘Amendmensofthe Unitd Saies Constituton. Thisrigh is nonegoiable nd cannor
< nfringed upon

“mendimeat 1 “Congres shall ke no law respecting a esablishment of relgion, or
prbibiing e re excrcie thercof or sbrdging the Feedoms o specch, o of he prss,
O he Fight ofte popleto prsceabi ssemble, and o petition the governmeotfora
redres of revances "
Amendment &: “The right o the people to be secur in thir persons, houses
and effects, sgainst unreasonable searhes and seiurcs, shall not b vigla
warants stalissu, but po probablecaus, supporte by Oath of Affminatien g
particulaly describing the plac t be sarched,and the person orhings o be sepe

mendment 14: Section 1) “Allpesons bom or naturalize in the Unitd St st
ubject the jurisdicton theref, ae citzensof the Unitd States and the State wperr,
they reside. No state shall make or enforce any law wi

shall abridge the privileges or
mmunities o ciizens of the United Staes;nor sl any stae deprive any person o 1.

Hiberty,or propery, without due process of the aw: nor deny to any person withn s
jurisdiction the equal protection of the laws.”

(Sestion 5) “The Congress shall havethe powes 0 cnforee, by sppropriat legisaion,
the provisions of this aticle.”

Therefore, ifprson offcial open prisonecrs legal mail then said prisoner has to be
present when opencd as according to law. Scc IWashingion ve. James, 743 F: 34 1)
@ cir. 1986).

Unfortunately, PCCOs ignore the law and maicinusly oppress theprisoncrs within
their car.

Py
!, and no

.
ecourse, 15 at esort o ebellon agint ryranny and opprcsion, ththuma s

should be protected by the rle of the law."
Indeed,in his speech entiled “The Perpetuation of Our Poitcal Institutons' Abrahar
Lincoln said, ..if the laws be continualy despscd and disrgarded, f het righe o
secure in ther pesons and property, re held by no hette tenure than the capricn
mob thealienaton of thei affections from the governmont i th raural consequence;
‘and o that sooner or lter, it must come.”
‘Therefore, PCCOS must uphold the law asisth
prisoners' legal mailor they are violating the Iaws
prociaim 10 stand for as agents of Amerikkka,

duty and cease to tamper wigh
ideas. and standards tha they

First & Fourteenth Amendments: Access to the Courts

“The First and Fourteenth Amendments guarantcesprisonerstherigh o access f the
court. This includes, but i no imited to, adequate low Iibraris that re accensibe
every prisoner.

Pontic Cormestional Center Offcals provide in-alequate law lirares (0 prisoners i
segegaton sats. The egal books withinthe sgregation awibrry are tom up an
otherwise defaced. See Bound vs. Smith, 430 U.S. 817, 975, Ct. 149] (v..the
fundamental constitutonalright of access 0 the courts requires prison autharities
assist inmates...by providing prisoners with adequate law libraries...)

The Constituional Right o access o the courts is s fundamental that the courty

eguire orprison ofcal 0 provide adoquae aw librarics o prisones. Sec Founger vy
Gilmore, 404 US. 15, 92. CL. 250, 30L Fd. 2 142 Tip. 149401500,

Books Required 1o be Available in Law Librarics
1) Relevant state and federal statutes;

2) State and Federal law reporter from the pact few decades:
3. Shepards citations; and
4) Basic teatses on habeas cor

s, prisoners” civil rights, and criminal I,
Howeve, he books must s b uscabl. In Pontae Correctional Cente segregaion
i the books ar ripped apart, missing pages, nd otherwise damaged. The g
e quch condition becaus the priso officialsae delibersely indiffrent n the
o not fllow the rosedure thy thenseves mplement. Sec PON 0348
Spcicaly,prisomoficials dono s prsoners bfoecnerin, e g e
S T sseregaion. This sl nthe danaging of e legal boks.

A sotr e requird hat L s be of e size, S Sharge s
e 24289 (7 Cir 1992 wnd Cepulois vs. Fir 132 F. 241 (1 Cr. 1894,

o brates with Pontiac Comectionsl Cener segregalion do ool me that
e . They are the s iz hcls o which prisonrs eside. Indcd,
i st el tha have beca convered into “law libeaies”

o (2) law s i Norh Cel House segrgtion. Each law ibrary
e e, ay conains two (2)shelvesofbooks,and only e (1) prisonce s
e given law braryatone tim. The law ibary canonly b used o0 3 st
e Mt 500 P Satuday hiough Thusday. And tese small aw s
e ncds of approxiniely four hudred prisoners st any given tme.

Neadless 0 53y, they ae inicequst

e el canno e vor i prisonr' ight 10 ccess o the couts. Sce
o Gl 313 US. 346,61 S Ce 610,85 EL 1034 1941), el inking
B ove th Law, Pontas Comectonal Cenir Offiials do abridge snd plr
e igh s o he cours by poviding and maitiin sl madquate
T librrics 1o prisoner wilhin segregation.

el have the iy o provide risoners with adequate lw libcaries Sce
o e 405 U 319,321, 52 1 1075 1081, 31 L d 24263 (197, wd
e Somchcombe, 412 US. 17, 34n.22.93 S Ci 1977, 1986, 36 L E4 24714

728(1973).

First & Fourteenth Amendments: Freedom of Religious Activity

e -Fre xcrsise Claue” of the Firs Aendnnt and e “Equal Proteion Clause”
o P Amendment peoect 4 pisoner' right 0 bave it inand xcris of
Seligion withoutbeingdiscriminstd against due 0 ther bele

vt Amendment of th Urited Suics Consttution says inpar;“Congress shall
otk o aw respectin an stablishmeat of eigion, o protibitig e fes exercse
thereof..”

s hat s citzens ofthe Urited Statesof Amerika prisoners bave he igft
o praiee religon ithout discrimination by priso auboris. As longas your belief s
s and s prisonoffcsls canno mpede youfom pracicing . S Love 5
‘Reed, 216 F. 3d 682 (8" Cir. 2002).

e e Comectonal Center Offcals obsisut prsoners o praciing Ui liious
e housed in North Cel House scgregation and placed on One Galley.
v e ight o et iha rligios eader and 10 annd eligious srvics of
i faith

“About once a week cither the by ontiae Correctional Center or religious

A . o the community vl hrough he stnion and sop at pisoncrs” cels o

o alny of North Cel House. Thus,denying iyt prsooers o theif igh 0
e ilh eligious leaders cach time that the religious

Prison offcals cannot treat members of any relgious domination different than others,
“This means that th fifty-two who reside on One Gallery of North Cell House are
guaranteed by law to have the opportunity 1o meet with religious leaders tht the other
e hundred risoers n North Cell Hous bave. Soe Gz vs. Bt 405 US. 319 )
(1972).

[n 2000, Congress passed the Religious Land Use and Insttutionalized Person Act
(RLUIPA) which protected prisoners" right o pracice their religious belefs. RLUIPA
tate tht aprison cannot *..impose a substantial burden on the religious exercise of a
‘person esiding i or confined 1o an intitution.” Sc Charles vs. Verhagen, ~F.3d—, No.
02-3572, 2003 WL 22455960 (7* Cir. Oct. 30, 2005).

However, by probibiting eligious tours of One Gllery in North Cell House, Pontiac:
Corectional Center Offcials do exactly what RLUIPA prohibit; they impose a
substantil burden on prisoners' religious belcts.

‘Their unethical and immoral - not to meation iliegal - behavior s not justified in any
way, shape, or form. Only when essential 0 prison security and discipline can prison
officias plac restricions on religious actvities. Sce Washington vs. Lee, 263 F. Supp.
327,331 (MD. Ala. 1966).

Being tha all of North Cell House is made up of prisoners who are in segregation status
or administraive detention the exclusion of prisoners on One Gallry of North Cell
House receiving relgious leaders is un-substantial and therefore cannot be deemed o5 s
precaution towards institutiona securityor discpline. 1f prisoners on the other seven
galleriesare allowed o meet with reigious leaders even though they are in segregation it
only goes to show that prisoners on One Gallery should be afforded the same right,

e, that 't the casc. Sadly, prisoners who are placed on One Gallery of North Cell
House ae treated diffrcatly than those on the other galleies of North Cell House for no
reasonable reason. This is a violaion of their right (0 equal protection as s forth i the
Fouteenth Amendment.

“All ersons bom or naturalized in the United Stats...are citizens of the United
States...No sate...shall abridge the prvileges...of citzens of the United States, nor shall
any stte deprive any person of lfe, liberty, or property...nor deny any person. ..cqual
protection of the laws." Fourtecnth Amendment of the United States Constitution.

Education

“The purpose of incarceration i rehabilitation of prisoners so that upon release from
prison they can re-nter society as safe and productive citzens.

Rehabilitation consists of, but i mot imited to, cducational and vocational classes,

therapy, counseling, and Narcotics Anonymous (N.A.) and Alcohol Anonymous (A.A.).

Pontiac Corectional Center does not offe any of these rehabiltative programs to

prisoners i segregation.

“Thisis a direct violation of any prison's mission; to rehablitate prisoners. Joan
Petersila sid in the article “Beyond the Prison Bubble” that it should not come as a
‘suprise toleam that we bave a corrections sysiem that does not comrect™ Indeed, why
should we expect our corrections system to correct when prison officials do not offer
rehabilitaive programs o the vast majority of prisoners? Partiularly, Pontiac
Corrctional Cener Offcials refuse o give prisoners i segregation any rehabiltative
programs (o participat in.

‘The Pontac Correctional Center Orientation Manual states on page 38 that prisoners
in segrogation status will be given access 10 educational classes upon request;

“(F) Edveation: (1) Offenders confined in segregation status may submit a request for
basic educalional materials. The Educational Faclity Administator (EFA) will review

N .
The majority of vomen in prisun are
cand use. Viomen bear the bruit o po
failing to earn enaugh marey to sure
chouse between staying out of 31 o

©80% of vomen In prison report inc
and 92 report incoines uider Sic

O Since 19k, 1

© 1979, et then bl o she
for nonviolent crimes

Wiite collar crime drains $200 billion per year from the US econuimy,,
is less than S5 billion, Finding a white collar criminal in most jisons, |
who can afford high-priced lawyers and witnesses rarely do il i
court appointed atlarneys who seldom have the time or resources Lo de

© The Savings & Loan frauds have cost US taxpayers at [

© The US now imprisons mare than Len times as many divg
dealers and users. Al the same (ime more than S250 bilion i diug
convictions for money laundering are fow and far betvicen.

135 il

et e property eiimes, such as checi forgery, check liting, and illegal credit
s that criminalize poverty, being sert 10 jail and placed un probation for

. AL {lz sie time, the satety nef has been slashed, forcing many women to . \;
din e Kids,

s of less than §2,000 per year [n the year befare their arrest,

Vison has increased by mpre than 275

aulin prisoi were there for nunjviolet ciinies. Togay, 70% are tivie

e the ecunanic cost of “stree} ctin
bisever, would e no'smal task, Thuse
& 1ose who can't must make €4 vith

i i in 1980, most of them los-{eved
ofits £ through US banks each year whili

the request along with the offender's educational level. The basic education material
appropriae o the educational level of the offender will be sent o the segregation unt for
the offender’suse. All mateial will be in th form of workbooks or worksheets. The
material will b retumed to the Educational Faciliy Aduministrator, evaluated and
‘additonal materials may be provided. 1z

“Note: Unlessspecifcally approved by the Office of Adult Education and Vocational
Services nd the Facility Chief Administrative Offcer,offenders in segregation status
il ot b eligibl to take the G.E.D. exam. No credit i given for mandate days or
EGCC whil in segregation satus. No offender will be abe o take the TABE. Test™

Pontiac Correctional Center Officals do not allow offender insegregation statis o
partake in any educationa classes. In allrality,prisoners are uoable 10 do 5o because of
the prison offcal’s oppressive estictons tht thy themselves aciliated. “No offender
will be able o take the TA B test”

“The T.ABLE. tesis th tet offenderstake o determine their educational level. By not
allowing prisoners o take the test while n segregation status, Pontiac Correctional
Officials effecively disqualify every prisonee within segregation from participating in
cducationa classes.

S the above reference; “The Educational Faility Adrministstor._will eview...the
offender's educationa levl. “By prohibiting pisoners from taking the T.A B.E. test
while in segregation staus the EFA is not able o review a requesting prisoner's
cducationallevel because a record of such does not exist. This results in the prisoner's
requestautomatically being denicd. This act is knowingly and willng commitid by
Pontiac Comectional Center Offcials 2 asystematic mode of oppression which is
perpetuated o that prisoners do not rehabilitate and therefore retum t0prison after
release, Remember, more pisoners equals more money for prison officials whie less
prisoner’s equals less money.

‘These procedures re in violation of DR 40550 which can be located on pages 39-40 of
the Pontiac Correctional Centr Orientation Mamual

“DRS04: Adult Basic Education Requirements for Offenders Commitid fo the Adult
Division o or aferJanuary 1, 1987:"

(3 Offenders who are commited o the Adult Division of the Department of
Correction on or afier January 1, 1987, fo two or more years, or who have been
commitied as Sexually Dangeros Persons, except those offenders serving cither a lfe
scatence or a death penaly senteace, will be given an achievement est within 20 days of
ther arivalat the Pontiac Corrctional Center. Offenders whose composite sorc in
reading and mathematics is below 6.0 (6" grade level) will b required to complete 90-
Ay stcadance program in rading and mathematics. Any exceptions o this requirement
must be made by both the Warden an the Suprinicndent of School District No. 28.
Failure to comply with this requirement may result in disciplinary action and/or
restriction of assignment pay.”

Obviously these two statements contadict each other, The irst sas, “No offender
shal take the T.A B.E. test” While the secood says, “Offenders who ae commitied o
the Adult Division of the Department of Corrections on o afer January 1, 1987....willbe
given an achicvement test within 20 days of their arival a th Pontioc Correctional
Center

However, the former is aregulation enforced by the PCCOs whil the late s the law.
Inrefusing o allow prisoner’s in segregation 0 take the TA.B.E. es, thy are breaking
the law; pure and simple. For the T.ABLE.test s the "achievement es” that i
‘mentioned in DR 405 50

“This means tha the Pontiac Corectional Center Offcials are ot lving up o their
mission s aid out in the Pontiac Correctional Center Orieniation Manua to
rehabiltate the prisoncr's under their auspices.

Due 10 thei tyrannical behavior the prisoner’s o Pontiac Correctional Center whoin
segregation are denicd cducational, and therefore rehabiltative programs. This resuls in
the degeneraton ofprisoner’s psyche and well-beng which culminates in high
recidivism rae amongst prisoners. 3

Eighth Amendment: Proteciion From Physical Brutality

“The Eighth Anmendment protctsprisoners from physical brtality undec the “Cruel and
Unusual Puishment” tandards. Thisincludes excessive force by guards within prisons.
See Hudson vs. MeMillan, 503 US. 1 (1993).

Employees at Pontiac Correctional Center know as Correctional Officers have a
repettive and violent history of brutally assaulting prisoncrs. Many prisoners have becn
viciously artacked by PCCOs because they have flooded teir cll, assaulied staff,
popped sprinklers, and used explicit language towards staff, Mosi of the tme prisoners
do these things as s means of proteting their oppressive treament.

‘The comectional officers of PCC have perfected a method of being able 1 safely beat
prisoncrs. First thy group together. Next they handcu and shackle the prisoner. And
then they attack him.

In Hudson vs. ke Millan, the Supreme Court found tha a prison guard's use offorce is
unconstituional when it i not spplicd “...n a good fath effot to maintain of restore
discipline” but s instead used to “malicously and sadisticaly cause harm.”

‘When someone is considering whether the force used s excessive or o, you would
have 1o considerte following:

1) The need for force.

2) Whether the amoun of force used was reasonable given the need.
3) How serious the need for force appeared to the guards.

4) Whether the guards made efforts t use as lte force s nccessary.
5) How badly you were hurt.

Using e method prefrre by the correciiona offcrs of Pontiac Correctional Center,
1 il now address ach of thos questions n ordes 0 demansuae the physical abuse
prsonersface by the hands of their guardians.

1) There i 0o need or fore if a prisones is aready consirained by handeuffs and
shackls. He poses o isk 10 anyone and he corectonal oficer’s ssault of is person
‘while he is consiraned by eanacles is unconsttutional and llegal.

2) As noted bove, her i o justficaton or the use offoee by comectional offcers
agansta prisoner who i bound by handcuffsand shackles i Defenselss).

3 The guards canno resonable proclai that ey belived ay force was necessary
‘when the forc n quetion was used agansta prisoner that was already resrsined.

4) As noted above inthe answer o No. 3, i a prisoneri bound by handcuffs i
shackis there cannotbe any reasonable excuse for using force aganst him. Thercfore,
any force that s sed i b considered as excessiv and cano be considered s the use
of“as e foce as necessary” because none was necessary!

“Therfore, e cousiderin th responses o hose five questions it s extremely casy o
s hat prisones of Pontac Correctional Cente ae being savagely attacked by the
cortctonal officers whose job and duty i i o protectand care for then. Such behavior
isllegal and humane. e Wilkin vs. Gaddy, 130.Ct. 1175 (2010); and Wiliams v
Jackson, 600 F. 3d 1007 (8* Cir. 2010).

Eighth Amendment: Right 1o Decent Conditons in Prison

“The Eighth Amendrment’ probibiton of crcland unusual pnishmentalso protets a
pisoner's ight o safc and somewhat decent conitonsinpriso. Sce Rhodes v
hapman, 452 US 377, 345.46 1015 CL 2392, 2398.99.69 L £d 2459 (1980). |

Sanitation:

Pontiac Correctonal Center Offcals knowingly and willingly foce prisoners tolive in
unsanitary conditions that are often dangerous to one’s health. What makes this even
‘more outrageous i the fact tha they could fx this problem if they wanted to. They
don't. The PCCOs are puting prisoners' danger with despicabl discases that
have the potential of being deadly andlor contagious (. Hepatits C, Staff Ifections,
Pocumenia, etc... This deliberste uncaring negligence is inhumane and illegal. See
Helling vs. McKinney, 509 ULS. 25 (1993).

Each cellwithin North Cell Fouse is equipped with a ven 5o that air can be circulated
hroughout the cell. However, these vents are never cleancd o they have accumulaied a
Significant amout of dust,lnt, and debris which makes them nonfunctionsl. Because of
al of the accumulated junk inthe vents the PCCOS are forced o keep them fumed off.
“This means two things - 1.)ai i the cell s not circulated; and 2. th prisoners can (and
sometimes do) suffe severe harm. See Gibbs vs. Cross, 150 F. 3d 962 (3" Cir. 198)

Prisopers are etitled to sanitary living conditions. See DeSpain vs. Uphoff, 260 F. 3d
965 (10" Cir. 2001); Martino vs. Carey, 563 F. Supp. 984, 1001 (D. Or. 1983); and Ruiz
ve Estelle, 503 F. Supp. 1265 (1980).

“Thisincludes the ight to have adequate cleaning sup

Once a week on Sundays PCCOSs issuc ane half cup of diluted disinfectant soap o each
prisoner. This halfcup i expected to work miracles. Firs, it is supposed 1o last a
Prisoner until the following Sunday. Secondly, it s supposed to be enough to properly
clean the walls, i . tolet, floor, door, chuck-hole, sk, and bed of the
prisoner' cel. Obviously hisis not enough disinfectant o meet those ulopien
expectaions.

1t would b quite simpl for PCCOs o give prisoners more disinfectant soap per week.
i cold be done one of two ways. 1, It could be tha they give prisoners a full cup every
Sunday; o 2.) They could give out onc half cup wice every week. Unfortunately, they
refus o docitherand force prisonersto liv in flthy environments

Ponti Correctional Center segregation houses those prisoners who have violated
institutional rles and ar being disciplined with solation. It is necdless to say that some.
of theseprsoners are mentally ll. These mentally il prsoners ae actally supposed to
be housed separately from the “sane” prisoners ~ they're not

“When a prisoner throws urineor feces onto the gallery (he walkway outside o the
cells) PCCOs leave it there and refuse o clean it up. The only time you wil s them
clean up the wastc i if cither the Werden or the Director of IDOC i about o tourthe cell
house.

S0, unless their bosses are coming through for an inspeciion, the only means of having
the wast cleancd upis on 1* shift when the medium-security prisoners tha act a5
janitors are n thecell house. This means tha if any wasteis thrown ono the gllery on
2% or % shift it wil emain there unilthe following day when the medium-security
prisoners come back in on 17 shift

Therefore, risoners have to put up with the smell toxic fumes, and insccts that co-exist
with such filth. Typically, when addressed about this problem PCCOs say “I'm not
cleaning it up. Wait unti day shift.”

Naurally one woud say, “Don't throw wast on the gallery.” And fyou saythat you
arecomect. Howerer, there i no possible way for prisoners 1 preven ober prisoners
from doing s0. We are in our cells twenty-four hours a day. Is

By forcingpisoners 1o lveinsuch it conditons the PCCOs e subjcting the
prisoners undertheir cae 1 cracl and unusual punishment. See Trop vs. Dulles, 356 US.
86, 101, 785 Cu. 390,598, 2 Ed 24 630 (1958); 30d Spain vs. Procunier, 600 F. 2d
0

These condiionsar unhealtky, inhumane, and dangerous. They can esut in scrious
sicknessand even deah. Prison officials have the responsibiliy (o et prisoners i
safe and sanitary envionment. See Coldman vs. Schwarzenegger, 2009 WL 2430520
(ED. Cal): 30 Farmer s Brennan, 511 US. 825, 114. Ci. 1970 (1994).

.. prison offical may be held iable under the Eighth Amendment for denying.
utmane conditons..only i thy know tha inmate face substantial ik ofseious barm
nd disregard that ik by ilng o (ak reasonable measures o abate i...” Farmer s
Bremnan.

Poutiac Conctional Center Oficialsarc aware ofthe sanitation violaions with PCC
and hey do pothing 1 abae those violtins.

Prsoners are also supposed 1 be given proper grooming supplis. Indeed,a prsoner is
expected o keep imself wel groomeed atallimes. See DR 502.100

However, this is not possibe due 1o PCCOS” alire t0 comply withinstitutional rules.
Page 23 of e Poniae Correctional Center Orieniation Marual saes tha prsoner e
lowed 1o have combs so it they can keep themselves groomed and presentabl. Yet,
PCCOS do ot band out fee combs 1o prisooers pon ther vl nordothey sellcombs
ou the commissary. See De 7861

Any prisoner who i nor wel groomed at all s will be ssucd a DOC 0317
Disciplinary Report. Sce Page 35 (4) of the PCCOM.

“The commissary sell ony a palm brush wich ismade ofcheap,fisy plasti. This
meas that Afikan- Amerikkkan prisoners cannot mainain thei grooming because the
palm brush breaksintheircurly, nappy hair. Inorder t0 keep her appearance.
prescotabl hey need a ommb o bair pick

"Alo,the commisary does not el prisoners insegregacion saus dentl 105 o s
srease. Hair greae s necessacy for Afrkan-Amerikkkan prisoners o keep their scalp
om drying out and peeling.

Without dental flos tatar ad plague build up around the guums i placestht ooth
brush cannot reach. Thisresuts in bad breath,Foting teth, and gum discase. There is
o penological nterest” i denying prisoners i segregation combs, reas, o dental
foss. The denil of such s a acic that PCCOS use 0 0ppress prisoners.

Lighting:

On One Galley of North Cel House all of thecells are Lt twenty-four bours a day.
“This cuses sensory deprivation from being,exposed to light constantly without reprieve

Sce LeMaire vs. Maass, 745 F. Supp. 623 (1990).

“This means that at all peiods of the day ffty-two prisoners in North Cell House are
being systemaicallytortured by excessive exposurs o light Placing prisoners in cell
tha s constantly it has the same effect as placing them in cels that are constanly dark.
...here is no evideoce tha...saff neds o see nto the...cels for 24 hours per day, or
thal they are even nearthe...cels for 24 hours per day. Defendant offered no reason
the clls could not bave switches outside so guards can see nto them when they must
LeMaire vs. Maass.

Instead of turning a light on, or using a fashlight to seeinto acell when necessary the
'PCCOs maintain 8 constant llumination of the cels on One Gallery of North Cel Hlouse
“Thereis no penological interest fo requiring plaintiff 1o suffr physical and
psychological harm by living in constant llumination. This practce is unconstituional.”
LeMaire vs. Moass.

Fourteenth Amendment: Du Process A

“The state shall not deprive “any person of if liberty, o property without due process
of the law.” This is known as the "Due Process Clause" of the Fourteenth Amendment.
‘When prison offcial violate tis right a risoner has a “liberty interest” See Wolf vs.
McDormell, 418 USS. $39 (1974); and Sandin vs. Connor, 515 US. 472 (1995).

Meal Loaf:

‘Whenevera prisoner of PCC segregation assaults another prisoncr ora guard the prison
offcals lace him on Meal Loaf status without the due proces ofa disiplinay hearing.
Before the prisoner is ound guily of the assaulthe s accused of commi
punished with Meal Loaf. If, after his
committng the assault he
illegal. See Fifh Amendment

"Meal Loafis the lelover scrap of any mesl tht re first grind up and them compacied
{ogether and baked nto brick. Prisonersare placed on Meal Loaffora mimimum of
thee days

I the past the courts have declared that Meal Loaf i, in el constituional. See
United States vs Michigan. 680 F. Supp. At 275: and Smith vs. Oregan State Dept.of
Correction, 101 Or. App. 539, 792 P. 2 109 (1990).

However, when Meal Loaf is used s a punishment for anything not o do with the
abuse offood or cating wensils it is unconstittional. Sec ZeMaire vs. Maass, 745 F
Supp. 623 (1990)

In LeMaire the court concluded that Meal Loaf s purishment s iegal. “T conclude
that theuse of Nutra Loaf a punishment violates plaintif"’s Eighth and Fourteenth
Amendments ights.™

The court ound a similasrling in Moss vs. Ward, 450 F. Supp. 591, 596 (WDN.Y.
1978). . prison offcials cannot impose such severe sanctions for breaking disciplinary
ule..when ther is o showing tha the prisoner is cngaging in the condut the ule
designed o provent.”™

See also Finney vs. Arkansas Board of Corrections, 505 F. 2d 194, 207-08 (8* Cir.
1974): and Finney vs. Hutto, 410 F. Supp. 251, 276 (E.D. Ark. 1976).

Onlyifa prisoner abuses his food orexting uteusils can he be placed on Meal Loaf
Assauling otberprisoners or guards is ot punishable by Meal Loaf. The court also
decided in Lemaire that feces and urine do ot constite the same 55 food. I prisoner
does throw urine or feces (as disgustingas thatis) be cannot be placed on Meal Loaf.

Pontiac Correctional Center Officials usc Meal Loaf as a purishment for several things
(. assultng sa, disespecting stff trowing feces andor uine, cc...)

Bt back t duc process - placing pisoners on Meal Loaf prior o being found uilty at
a disciplinary heariog violates the prisoner’srightto due process. In Wolffvs. McDonnell
the court cleary declared that prisoner have therigh t a disciplinary hering beforc
being punished for an alleged rue infaction.

Strip-Out: 7

Pontiac Conectional Cenier Officials have tendency of sipping out (iking away all

of ther property) or various rule infractons but they do so unconsttutionaly for two (2)
Firs, the Segregation Procedure Manal, which s published by the Department of

Corections,sys o page 7 hat prisoncecan ol b sriped out fo te following:

1) Helights a fire in is cel.
2) He floods his cell
3) He hams himself.
4) He hams somebody else
5 He damages or misuscs staie propery.

Pontise Coretional Center Officals strip out prisoner for reasons oher than the five:
listed above. 1fa prisoner i being loud or is found possessing any contraband he will be
sripped out.

In LeMaire the ourt found that the use of scip-out tatus for anything other than the
abuse of property s unconstiutional. Therefore, not oaly s it unconstinutional to strip-
ot a prisoner for being loud or possessing contraband, it s also unconsttutional to strip-
out a prisoner for any of the first four reasons lsted on page 7 of the Segregation
Procedure Manual.See Wright vs. Rushen, 672 F. 24 t 1133; and Estelle vs. Gamble,
129U, a1 103,97 e a1 290.

Secondly, PCCOS do notallow prisoner 10 prove ther innocence of alleged rule
infractions before stripping them out. This practic is unconstitutionel.

Disciplinary bearings exist 5o thatan offender can prove his innocence before being.
‘punished for something he may in fact not be guilty of. Stripping a pisoner out before.
he is found guily at disciplinary hearing i the equivalent of exccuting someone.
withouta tial o determine their guiltor innocence

Prisoners have the right o prepare a defense before their disciplinary hearing.
However,due tothe fact that prisoners are strpped out for 8 minimum of seventy-two
hours it makes it extremely difficult - if not impossible — 0 do so.

In ssence, PCCOs are in violation of the law as pursuant to LeMaire in regards to
using strip-oul satus a5 a punishment for anything other than the abuse of
propentylclothing and preventing prisoners fom preparing proper defense at their
disciplinary hearings by stripping them out before they are found guily.

Conclusion

“Thisreport s been prepared not o shed light on only one injustice perpetuated by
Pontisc Correctional Center Officals but 0 show a wide spectrum of cveats commiticd
by said officials of Pontiac Correctional Center that are oppressive o the prisoners.
‘confined within saidinstituton.

“These multipl infractions of the United States Constituton have resulted in severe
‘physical and psychological harm 1o the prisoners detained within Pontiac Correctional
Center. Very recenty it was found that such conditions are unconstitutional and
herefore llegal. See Coleman vs. Schwarzenegger, 2009 WL 2430820 (E.D. Cal).
Injunctive Relief N4

In Tightof the information provided throughout tis report o the oppression of
within Pontiac Correctional Ceater it is demanded by — not the author o
prisonersof Pontiac Correctional Center individually ~ humanity as a whole tht these
oppressive acions be remedied through the following.

1) Thatthe Pontss Corretional Center Offcials stop theilicgal banning of publiations
hat have o penological interest o the intitution and tht the kecping of alst of banned.
jeations be ceased due to the legality of such a list.
2 That the legalopening of prisoners*Jgal mail outsideof ther presence be stopped
enmedintelyand any prison officialfound guilty of iegall opening legal mail be
severely puished.
) That te law librares be enlarged and that prison officials ollow guidelnes to
prevent the daraging of egal books. Also, that all damaged legal books be replaced.
> That Poniac Corctional Center Offcials allow prison=rs confined on One Gallery
of North Cel House o meet with eligious leaders asthee i no penological interest n
denying them ths right.
5 "That pon arival at Pontiac Correctional Center all prsoners senenced o two o
‘more years - exceptthose serving e or death penalty seatences - b given the TAB.E.
st within 20 days and that prisoners in segregation status b allowed to partcipate n
cducational clases
16 That the habitual use of excessive force against prisone: by Poutiac Corectional
Center Correctional Officers be put 0. stop. That camers's be placed on every gal
and in every staiwell 1 belp prevent the use of excessive force. And that rison off
found gty of sing excessive force against prisoners be severely punished.
7y That prsoners be issved mre than a haf cup o disinfectant soap per week. Eiher
by ssuing ooe fllcup every Sunday orisuing two halfcups o prisonersevery week.
“Thatthe veats b periodically cleaned. That the cleaning of any and all bodily luids and
wastes be done prompily and efficienty. And tht prisoner's be llowed to purchase
Combs, grease,and dentl loss off ofthecomissary. And that the cel on One Gallery
of North Cell House nor be lluminated twenty-four hours et day.
8 Thatthe use of Meal Loaf s a punishment for anything othe thanthe abuse of food
o cating wtensilsbe stopped. That the pratice of placing prisoners on Meal Loaf before.
they are found gty of busing teir food and eating utensils be stopped. Thatthe use of
irip-ou staus 4 a punishment for anything otherthan th abuse of property and clothing
be stopped. And that the praciceof placig,prisoners o sirip-out status before they are
found guily of abusing their property and clothing be put >3 stop.

s a collective whole of civilized humasity it is demanded that vry one of tese

remedies be met - with NO xceptions! To not abnegate o these demands s to alicnate
oneself from the civilized world and into a barbaric ightmare. - For prisoners are humans
and therefore they have rights.

3)
34)

35)
36)
37)

38)
39)
0y
41)
a2)
a)

References 9

Tumer vs. Saley, 482 US. 78 (1987)

Thomburgh v. Abbott, 490 U.S 401, 404 (1989)

Willams v. Brimeyer, 116 F. 34 351 (8* Cir. 1997)

DR 525210(s)

Departmental Kule 504.209 Dangerous Writien Material
Department Rule 504.308 Contraband or Unauthorized Property
Departmental Rule 504310 Abuse of Prvileges

Departmental Ruke 504.403 Disobeying a Direct Order
Departmental Rule 504.404 Violaton of Rules

'DOC 0317 Disciplinary Report

Gates vs. Coller, 501 F. 24 1291 (* ir. Sept. 20, 1974)
Procunir vs. Maninez, 416 U.S. 396 (1974)

Bach vs. Peopl of the Stat of lnois, 504 F. 24 1100 (7 Cir. 1974)
Adams vs. Carson, 488 F. 24 619 (7* Cir. (1973)

Moore vs.Ciccane, 8® Cir. 1972, 459 F. 24 574

McCray vs. Sullivan, $® Cir. 1975, 509 F. 24 1332

Pontac Correcional Center Orieuation Manual pg. 17

Castillo vs. Cook County Mail Room, 990 F. 24 304 (7* Cir. 1993)
Bacdow vs. Amiss, 477 . 24 89,898 (5° Cie:1973)

Taylorvs. Seret, 532 F. 24 462 (5° Cir June 1, 1976)

Frye vs. Henderson, 474 F. 2d 1263 (5* Cir. 1973)

Cruz vs. Hauk, 475 F.2d 475 (5" Cir. 1973)

Smith vs. Robbins, 454 F.2d 696 (1 Cis 1972)

‘Wolff vs. McDonell, 418 U.S. 539, 945. Ct. 2963, 41L. E4. 24 935
574

‘Washington vs. James, 782 F. 2d 1134 (2 Cir. 1986)

“The Perpetuation of Our Pliical nstitutions” by Abraham Lincoln
Bounds vs. Smith, 430 U.S. 817, 975. Ct 1491

Younger vs. Gilmore, 404 US. 15, 925, Ct. 250, 30L. E4. 24 142
Pp1494-1500

Pon 0348

Sthango vs. Jurich, 965 F. 24289 (7* Cir. 1992)

‘Cepulons vs. Fair, 732 F. 24 | (1 Cr. 1984)

Expure Hull, 312 USS. 546,61 5. Ct 640, 85L. E4. 1034 (1941)
Cruz v. Beo, 405 US. 319,321, 92 5. CL 1079, 1081, 31 L. Ed 24 263
)

Chuffinvs. Styncheombe, 412 US. 17 340. 22,93 5. 1977, 1986, 36
L E424714, 728 1973

Love vs. Reed, 216 F. 3d 682 (8 Cir 2002)

Religious Lund Use and Insitutonalized Persons Act

Charles vs. Verhagen, - F.3d -, No. 23572, 3003 WL. 22455960 (7" Cir
0ct30,2003)

Washington vs. Lee, 263 F Supp. 27, 331 (M.D. Ala 1966)

yond the Bubble” by Joan Petrsilia

Pontiac Corectional Center Orieatation Manual pg. 38

DR 405.50

Pontiac Correctionsl Center Orieatation Manial pp. 3940

Hodson vs. MeMillan, 503 US. 1 (1992)

44) Wilkins vs. Gaddy, 130, C1. 1175 Q0100

45) Willamsvs. Jockson, 600 F. 34 1007 (8" Cis 2010)

46) Rhodes vs. Chapman, 452 US. 337, 34546, 101 5. C1. 2392, 2398.99, 69
L Ed. 24 59 (1980)

47) Helling vs. McKinney, S09 US. 25 (1993)

48) Gibbs va.Cross, 160°F 34962 G Cir 1998)

49) DeSpin vs. UphofT, 264 34965 (10% Cir 2001)

50) Martino va. Carey, 563 F. Supp. 984, 1001 (D. Or. 1983)

51) Ruiz vs. Estlle, S03 F. Supp. 1265 (1980)

52) Tropva. Dulles 356 USS. 86, 101, 78S, CL. 590, 598, 2 L Ed 24 630
(1958)

53) Spain vs. Procunie, 600 F. 24 t 200

54) Coleman vs. Schwarzencgger, 2009 WL, 2430820 (ED, Cal)

55) Fammer vs. Breanan, 511 US. 825, 1145, CL 1970 1994)

56) DR502100

57) Pontiac Correctional Center Orientation Manual pg. 23

58) DCT861

59) Pontiac Corrctional Center Orentation Manul g 15

60) LeMaire vs. Maass, 745 F. Supp. 623 (1990)

61) Sendinvs. Conner, 515 US. 472 (1995)

62) Fifth Amendment

63) Urited States vs. Michigan, 680 F. Supp.at 275

64) Smith vs. Oregon Sate Dept. of Correction, 101 Or. App. 539,792 . 24 .
109 1990)

65) Moss vs. Ward, 45OF. Supp. 591, 596 (WDN.Y 1978)

66 Finney vs. Arkansas Board of Corrections, 05 F 24 194, 207-08 (8 Cir
1978)

67) Finney va. Hutto, 410 . Supp 251, 256 (ELD. Ark. 1976)

8) Segrogaion Procedure Maul pg. 7

69) Wright vs. Rushen, 642 F 24 a 1133

70) Esille v, Gamble, 429 US. at 103,97 5. CL a1 290

About the Author

Matthew Smith is a 20 year old political prisoner confined within
Pontiac Correctional Center segregation. He is a communist
revolutionary and is the leader and founder of the Political Party |
$.0.B. (Soldiers of Bondage). Anyone who wishes to contact him

may do so at the following address:

Matthew Smith B86629
Pontiac Correctional Center
P.0.Box 99
Pontiac, IL 61764