In Mitchell v. Peoples, the United States Court of Appeals for the Eleventh Circuit addressed a pro se complaint brought under 42 U.S.C. § 1983 by Rico Mitchell, a pretrial detainee, alleging that certain county jail officials violated his constitutional rights. Mitchell alleged that the defendant jail officials—Detective Simpson, Sergeant Peoples, J.M. Perkins (a mail clerk) and Sargent Clark (the mailroom supervisor)—violated his First Amendment right to free speech by confiscating and reviewing all his incoming and outgoing mail outside his presence, including his legal mail. The United States District Court for the Middle District of Florida denied the defendants’ motion to dismiss Mitchell’s claims on qualified immunity grounds. On appeal, the Eleventh Circuit affirmed the district court’s ruling, holding that the defendants were not entitled to qualified immunity because Mitchell demonstrated that (1) the defendants’ conduct violated his constitutional rights, and (2) their conduct was clearly established as unlawful.
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