U.S. Appeals Court: DELAY DELIVERY.

• Position: Brief Article

Rowe v. Shake 196 F.3d 778 (7th Cir. 1999). A state prisoner and a person who was his frequent correspondent filed a [section] 1983 complaint against prison employees alleging violations of their First Amendment rights and of the prisoner's due process rights resulting from delays in incoming mail sent by the correspondent. The district court dismissed the claims and the appeals court affirmed. The appeals court held that although the correspondent had standing to assert a violation of his First Amendment rights, the relatively short-term and sporadic delays in the prisoner's receipt of mail...