Quinn v. Doe (amicus)

In 2022, the Ohio Department of Rehabilitation and Corrections (ODRC) formally made effective a policy that fundamentally altered the treatment of legal mail from attorneys and courts in Ohio’s prisons. Prior to the change, the Ohio Administrative Code defined “[l]egal mail” as “mail addressed to an inmate clearly bearing the return address of . . . [a] court of law” or other legal entities.). In other words, any correspondence addressed to an incarcerated person clearly bearing the return address of a court was designated and treated as “legal mail”—meaning it was logged and could be opened and inspected, but not read, only in the presence of the prisoner it was addressed to.

After the policy change, a court’s return address was no longer enough to have legitimate legal mail be treated as such. Instead, for the purported purpose of combatting contraband coming into ODRC-administered prisons through fake legal mail, the new policy necessitated a time-consuming process requiring courts and other legal entities to register with ODRC, get that registration validated by ODRC staff, and then obtain unique control numbers from ODRC—which expire after twenty-one days—for every piece of correspondence sent to prisoners in order for that mail to be treated as “legal mail.” Under this new policy, mail from state and federal courts that did not bear a valid control number was “automatically treated as regular mail, regardless of the return address on the envelope”—meaning it was handled outside the prisoner’s presence, not logged or tracked, and subject to certain restrictions, like a five-page limit, to which legal materials with a valid control number were not subject. And, perhaps most egregiously, it allowed legal mail from the courts to be opened, read, and processed outside the prisoner’s presence even when the prisoner has specifically requested otherwise.

Plaintiff Jeremy Quinn, Jr., then an incarcerated individual at Toledo Correctional Institution, challenged this policy and brought suit in April 2022 after his legal mail from state and federal courts was repeatedly opened, read, and processed outside his presence, despite his explicit requests to the contrary. Quinn alleged that his mail was subjected to this treatment because courts refused to comply with ODRC’s arduous registration and control-number requirements—even after he reached out and asked that they do so—with court clerks at both the state and federal levels stating that the policy was too “burdensome” and “impossible” to follow given the volume of cases they handle. ODRC’s control-number policy restructures how court correspondence functions inside Ohio prisons.

After receiving multiple complaints from federal courts about the policy, ODRC currently exempts federal courts from the policy informally and in practice. Yet it continues to maintain that the policy as applied to all courts is somehow critical to combating contraband. Worse, Defendants have not put forward any persuasive reason as to why federal courts should be treated differently from state courts—an arbitrary distinction that undermines any claim of rational justification.

The policy shifts constitutional protection away from the nature of the mail—whether it comes from a court—and makes mail access depend instead on administrative compliance by third parties outside the prison system. In practice, that means legal protections turn on whether hundreds of separate federal and state courts, operating under their own procedures and constraints, elect to participate in ODRC’s registration system. Many have not. Worse, ODRC does not even apply its own rule as written. It purports to informally exempt federal courts, creating an ad hoc two track regime untethered to any standard. And ODRC has repeatedly demonstrated it cannot administer the policy consistently. Implementation has been chaotic—so much so that courts have had to issue case-specific orders to ensure delivery of routine court mail and have sanctioned ODRC officials for violating those orders.

ODRC’s policy as applied to courts of all levels violates prisoners’ First Amendment rights to receive legal mail and to keep its contents private.

Representing himself, Jeremy J. Quinn, Jr., a man incarcerated in an Ohio prison, sued ODRC and several of its officers in the Federal District Court for the Northern District of Ohio on April 25, 2022. He was appointed counsel to assist in his suit. After cross-motions for summary judgment in late 2024, the District Court ruled against Mr. Quinn on February 6, 2025. Mr. Quinn appealed the Court’s decision to the Sixth Circuit Court of Appeals on October 22, 2025 and was again appointed counsel.

Mr. Quinn filed his Appellant Brief on March 17, 2026.

Along with the Human Rights Defense Center, New York State Defenders Association, and Public Accountability and Uptown People’s Law Center, the ACLU and ACLU of Ohio submitted an amicus brief in support of Mr. Quinn on March 25, 2026. The brief was written by Shunhe Wang of the law firm Kellogg, Hansen, Todd, Figel & Frederick LLC. Appellees’ Brief was submitted on May 18, 2026. Mr. Quinn submitted a Reply Brief on June 8, 2026.

Oral argument was held October 22, 2026.