Case 4:25-cv-05162

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ECF No. 1

filed 11/25/25

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Page 1 of 18

Katherine Chamberlain, WSBA #40014
Jesse Wing, WSBA #27751
MacDonald Hoague & Bayless
705 Second Avenue, Suite 1500
Seattle, Washington 98104-1745
206-622-1604

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF WASHINGTON

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HUMAN RIGHTS DEFENSE CENTER,
No.
Plaintiff,

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COMPLAINT

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v.
DEMAND FOR JURY TRIAL
WALLA WALLA COUNTY, and
STEVEN BARKER, individually and in
his official capacity as Jail Commander
of the Walla Walla County Jail/Walla
Walla County Corrections Department,
Defendants.

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I. NATURE OF THE CASE

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1.1

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Defendants have adopted and implemented mail policies, practices,

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and customs that unconstitutionally restrict correspondence sent to prisoners, that

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prohibit books and magazines and legal materials, and that do not afford due

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process notice and an opportunity to challenge the censorship decisions as required

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by the United States Constitution.

COMPLAINT - 1
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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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Plaintiff Human Rights Defense Center (“HRDC” or “Plaintiff”)

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brings this action for damages, declaratory, and injunctive relief to end

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Defendants’ unconstitutional policies, practices, and customs, and to remedy

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Defendants’ censorship of Plaintiff’s publications and correspondence sent to

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prisoners at the Walla Walla County Jail in violation of the First Amendment and

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the Fourteenth Amendment’s Due Process Clause of the United States

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Constitution.
II.

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2.1

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PARTIES

Plaintiff Human Rights Defense Center (HRDC) is a Washington

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State not-for-profit charitable organization with its principal place of business in

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Boynton Beach, Florida. HRDC publishes and distributes books and magazines to

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incarcerated people across the country.
2.2

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Defendant Walla Walla County is a municipal corporation formed

under the laws of the State of Washington.
2.3

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Defendant Steven Barker is the Commander of the Walla Walla

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County Jail. Commander Barker is employed by and is an agent of Walla Walla

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County. Barker is responsible for overseeing the Corrections Department of

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Defendant Walla Walla County, which includes overseeing the operation of the

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Walla Walla County Jail. He is responsible for supervising the implementation of

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the Jail’s publication ban and other mail policies or practices. All of his acts and

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omissions alleged herein occurred within the scope of his employment, under color

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of state law.

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//

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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

Case 4:25-cv-05162

III.

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3.1

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ECF No. 1

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JURISDICTION AND VENUE

This action arises under the First and Fourteenth Amendments to the

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United States Constitution and 42 U.S.C. § 1983. This Court has jurisdiction over

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this action under 28 U.S.C. §§ 1331, 1343, 2201, and 2022.
3.2

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Venue is proper in the Eastern District of Washington under 28 U.S.C.

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§ 1391(b)(2) because a substantial part of the events complained of occurred in this

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District, and because the Defendants reside in this District.
IV.

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4.1

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FACTS

For more than 35 years, the core of Plaintiff HRDC’s mission has

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been public education, prisoner education, advocacy, and outreach in support of

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the rights of prisoners, pretrial detainees, and other incarcerated people who seek

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legal redress for infringements of their constitutionally guaranteed and other basic

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human rights. Prisoners of all types, family and friends of prisoners, and prisoner

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advocates, are among the intended beneficiaries of HRDC’s activities.
4.2

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To accomplish its mission, HRDC publishes and distributes books,

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magazines, and other materials containing news and analysis about prisons, jails

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and other detention facilities, the rights of prisoners, pretrial detainees, and other

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incarcerated people, court rulings, management of prison facilities, prison and jail

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conditions, and other matters pertaining to the rights and interests of prisoners and

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pretrial detainees, and other incarcerated people. HRDC also engages in advocacy

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and litigation to further its mission.
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Through its publishing project, HRDC engages in core protected

speech and expressive conduct on matters of public concern including: the

COMPLAINT - 3
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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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operation of correctional facilities; prison and jail conditions; the health and safety

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of prisoners; the constitutional and human rights of prisoners; and political speech

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and social commentary.
4.4

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HRDC’s educational, political, and legal publications and

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correspondence are entitled to the highest protection afforded by the United States

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Constitution.
4.5

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Sending publications through the mail to prisoners and other

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incarcerated people is essential to accomplishing the mission of HRDC. One of

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HRDC’s primary goals is to communicate with prisoners about developments in

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the law and protection of one’s health and personal safety while in prison or jail.

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Reading enables prisoners to engage in productive activity rather than sitting idle,

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thus helping to avoid conflicts and incidents of violence in correctional facilities

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and encouraging lawful methods of dispute resolution. In addition, reading helps

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prisoners keep their minds sharp, preparing them to become productive citizens

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when released back into society. Through prisoner education, HRDC’s mission, if

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realized, has a salutary effect on public safety through prisoner rehabilitation and

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lower rates of recidivism.
4.6

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HRDC distributes its publications to incarcerated people by sending

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its publications to correctional facilities all over the country, including in the State

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of Washington, at the Walla Walla County Jail and elsewhere. In particular,

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distributing HRDC’s legal educational publications to individuals incarcerated in

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county jails, such as the Walla Walla County Jail, is essential to HRDC’s mission,

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because the publications are designed to assist incarcerated individuals who are

COMPLAINT - 4
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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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subject to ongoing criminal proceedings, or who need to know about their civil

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rights while incarcerated in order to exercise or vindicate those rights, including

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the right to humane housing conditions, to access appropriate medical and mental

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health care, to receive disability accommodations, to be free from race and sex

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discrimination, to be protected from harm by others, and to receive mail and

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communicate with others, among other rights.
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HRDC publishes and distributes an award-winning monthly magazine

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titled Prison Legal News: Dedicated to Protecting Human Rights (“Prison Legal

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News”), which contains news and analysis about correctional facilities, the rights

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of prisoners, court opinions, prison and jail conditions, excessive force, and

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religious freedom. In 2013, Prison Legal News received the First Amendment

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Award from the Society of Professional Journalists. Prison Legal News is

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published on newsprint bound by two small staples, and is 72 pages long.
4.8

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HRDC publishes and distributes a second monthly magazine called

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Criminal Legal News, which contains news and analysis about individual rights,

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court rulings, and other legal issues related to the criminal justice system. Criminal

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Legal News is also published on newsprint by two small staples, and is 56 pages

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long.
4.9

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HRDC publishes or distributes various soft-cover books on prisoners’

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rights and issues related to criminal justice, corrections systems, health and safety,

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and legal issues that are of interest to prisoners and others, including reference

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books that provide prisoners with information they can use to help themselves and

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improve their lives.

COMPLAINT - 5
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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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4.10 HRDC publishes and distributes the book titled Prisoners’ Guerilla

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Handbook: A Guide to Correspondence Programs in the United States and

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Canada (“Prisoners’ Handbook”), which provides information about enrolling at

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accredited higher educational, vocational, and training schools.
4.11 HRDC is the sole national distributor of the book titled Protecting

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Your Health and Safety, which describes the rights, protections, and legal remedies

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available to persons concerning their health and safety while they are incarcerated.

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4.12 In addition to its publications, HRDC communicates with incarcerated

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persons by mailing them: (i) informational brochure packets (“Info Packs”), which

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contain a brochure and subscription order form, a book list, and a published books

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brochure (each of which is a single page); (ii) letters that provide pertinent

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information about HRDC’s publications and related topics, including subscription

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renewal letters sent to subscribers to its magazines when the subscriptions are

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nearly over, in the hopes of renewing the subscription; and (iii) Fundraiser Packs,

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which contain all of the materials included in an Info Pack, along with a one-page

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annual fundraiser notice and a two-page letter asking HRDC supporters for

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donations.
4.13 HRDC also maintains a website containing information about legal

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resources. The website contains information about breaking news and a database of

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articles, publications, legal briefs, and other information about state and federal

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issues affecting prisoners. Individuals can visit this website and view the content or

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become a member of and search for and print articles of interest to them, for

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themselves, or to send to others, including to prisoners who do not have access or

COMPLAINT - 6
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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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have limited access to computers or the internet, or who have limited or no

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research skills.

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4.14 On July 26, 2024, HRDC mailed the June 2023 issue of Criminal

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Legal News and the November 2022 issue of Prison Legal News to each of the

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following prisoners at the Walla Walla County Jail:

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Prisoner Name:

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Jedadiah Roller

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Ryan Vandenburgh

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Brandon O’Neel
Kimberly Day

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The individuals named above were incarcerated at the Walla Walla County Jail

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when the jail received the issues of Criminal Legal News and Prison Legal News

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mailed by HRDC in July 2024.
4.15 On July 26, 2024, HRDC mailed an Info Pack to each of the following

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prisoners at the Walla Walla County Jail:

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Prisoner Name:

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Jedadiah Roller

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Ryan Vandenburgh

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The individuals named above were incarcerated at the Walla Walla County Jail

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when the jail received the Info Packs mailed by HRDC in July of 2024.

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//

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//

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//

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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

Case 4:25-cv-05162

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4.16 On August 8, 2024, HRDC mailed the book Protecting Your Health

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ECF No. 1

and Safety to each of the following prisoners at the Walla Walla County Jail:

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Prisoner Name:

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Jedadiah Roller

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Christopher Bender

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Kimberly Day

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The individuals named above were incarcerated at the Walla Walla County Jail

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when the jail received the copies of the book Protecting Your Health and Safety

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mailed by HRDC in August 2024.

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4.17 In September 2024, HRDC mailed the September 2023 issue of

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Prison Legal News to the following prisoner at the Walla Walla County Jail:

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Prisoner Name:

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Ryan Vandenburgh

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The individual named above was incarcerated at the Walla Walla County Jail when

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the jail received the copy of Prison Legal News mailed by HRDC in September of

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2024.
4.18 On October 11, 2024, HRDC mailed follow up letters to each of the

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following prisoners at the Walla Walla County Jail:

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Prisoner Name:

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Ryan Vandenburgh

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Kimberly Day

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The individuals named above were incarcerated at the Walla Walla County Jail

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when the jail received the follow up letters mailed by HRDC in October 2024. The

COMPLAINT - 8
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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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filed 11/25/25

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letters notified each of these prisoners that HRDC had mailed them an Info Pack

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and publications, which they should have received by October 11. HRDC’s letter

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asked each prisoner to notify HRDC whether the prisoner had received the items.

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4.19 On December 6, 2024, HRDC mailed a Criminal Legal News

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expiration letter and a Prison Legal News subscription expiration letter to the

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following prisoner at the Walla Walla County Jail:

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Prisoner Name:

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Kimberly Day

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The individual named above was incarcerated at the Walla Walla County Jail when

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the jail received the subscription expiration letters mailed by HRDC in December

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2024.
4.20 On December 6, 2024, HRDC mailed a Criminal Legal News renewal

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letter and a Prison Legal News renewal letter to the following prisoner at the Wall

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Walla County Jail:

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Prisoner Name:

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Ryan Vandenburgh

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The individual named above was incarcerated at the Walla Walla County Jail when

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the jail received the expiration letters mailed by HRDC in December 2024.
4.21 On December 16, 2024, HRDC mailed a Fundraiser Pack to each of

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20

the following prisoners at the Walla Walla County Jail:

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Prisoner Name:

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Ryan Vandenburgh

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Robert Lucero

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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

Case 4:25-cv-05162

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filed 11/25/25

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Kimberly Day

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The individuals named above were incarcerated at the Walla Walla County Jail

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when the jail received the Fundraiser Packs mailed by HRDC in December 2024.
4.22 On February 4, 2025, HRDC mailed letters to each of the following

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prisoners at the Walla Walla County Jail:

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Prisoner Name:

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Robert Lucero

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Kimberly Day

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The individuals named above were incarcerated at the Walla Walla County Jail
when the jail received the letters mailed by HRDC in February 2025.
4.23 On May 29, 2025, HRDC sent two subscription renewal letters to the

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following prisoner at the Walla Walla County Jail:

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Prisoner Name:

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Kimberly Day

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The individual named above was incarcerated at the Walla Walla County Jail when

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the jail received the subscription renewal letters sent by HRDC in May of 2025.

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4.24 Between July 2024 and June 2025, Defendants rejected at least

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twenty-seven (27) of the items that HRDC mailed to prisoners at the Walla Walla

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County Jail, including:

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4.24.1

four (4) issues of Criminal Legal News;

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4.24.2

four (5) issues of Prison Legal News;

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4.24.3

three (3) Fundraiser Packs;

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4.24.4

three (3) copies of Protecting Your Health and Safety;

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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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4.24.5

four (4) follow up letters;

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4.24.6

four (4) renewal letters; and

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4.24.7

two (2) expiration letters

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4.24.8

two (2) Info Packs.

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HRDC marked with either an ink stamp stating, “Return To Sender,” or ink
marking stating, “RTS” , or substantially similar markings reflecting that
Defendants rejected them. In some instances, the mail was returned to HRDC with
a marking of “no longer here” or “NIC,” indicating the intended recipient of the
mail was not incarcerated at the Jail, despite records showing that the intended
recipient was still in custody. In other instances, Defendants returned the mail to
HRDC without providing any explanation at all about the reason for censorship or
rejection.
4.26 Upon information and belief, Defendants also failed to deliver other
copies of regular subscriptions magazines mailed directly from HRDC to various
prisoners at Walla Walla County Jail, including hundreds of copies of its
magazines, Prison Legal News and Criminal Legal News, between July 2024 and
September 2025. The prisoners to whom HRDC addressed and mailed those legal
news magazines were incarcerated at Walla Walla County Jail on the date Plaintiff
first started sending their six-month subscriptions, and many likely thereafter.

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4.25 Defendants returned the items identified in the preceding paragraph to

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4.27 In total, Plaintiff has sent at least 385 items of mail to prisoners at the
Walla Walla County Jail between July 2024 and September 2025, including
Protecting Your Health and Safety books, the Prisoners’ Handbook, issues of
COMPLAINT - 11
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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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Prison Legal News magazine, issues of Criminal Legal News magazine, letters,

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Info Packs, and Fundraiser Packs. On information and belief, Defendants have

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rejected all or most of these items of mail and have routinely failed to provide due

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process notice and an opportunity for Plaintiff to be heard.
4.28 The Walla Walla County Jail lists a publication ban prominently on its

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official website, stating that: “The Walla Walla County Correction’s Department

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will not accept any books or periodicals as each prisoner is supplied with a tablet

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with that information for free.”
4.29 HRDC’s books, magazines, Info Packs, Fundraiser Packs, and letters

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are not on the tablets provided to prisoners at the Walla Walla County Jail.
4.30 Defendants have rejected and are rejecting HRDC’s books,

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magazines, Info Packs, Fundraiser Packs, and letters, pursuant to their publication

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ban, or other written or unwritten policy or practice.
4.31 Defendants have rejected and likely are rejecting books and other

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publications pursuant to the Jail’s publication ban, or other written or unwritten

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policy or practice.

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4.32 Defendants have a written policy, practice, custom, or usage of

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rejecting books and magazines, and other publications sent to prisoners at the

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Walla Walla County Jail.

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4.33 Defendants have an unwritten policy, practice, custom, or usage of

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rejecting information about publications and other correspondence sent to prisoners

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at the Walla Walla County Jail.
4.34 Defendants have an unwritten policy, practice, custom, or usage of

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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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rejecting mail sent to prisoners at the Walla Walla County Jail without providing

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notice of the reason for rejection or an opportunity to be heard to challenge the

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decision.

4

4.35 In fulfillment of its mission, HRDC wants to and intends to continue

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sending its books, magazines, and correspondence to subscribers, customers, and

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other individuals incarcerated at Walla Walla County Jail in the future.
4.36 Absent relief from this Court, Walla Walla County Jail’s policies,

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8

practices, customs, and usages, including its publication ban and other restrictions

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on mail, chills and interferes with HRDC’s right to communicate with prisoners at

10

the Walla Walla County Jail, the rights of others to communicate with people

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incarcerated at the Jail, and the rights of prisoners at the Jail to receive those

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communications and publications, and will continue to do so.
4.37 Defendants’ written and unwritten policies, practices, customs, or

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usages, violate the First Amendment.
4.38 Defendants’ written and unwritten policies, practices, customs, or

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usages violate the Due Process Clause of the Fourteenth Amendment.
4.39 Defendants’ written and unwritten policies, practices, customs, or

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18

usages unconstitutionally burden and interfere with the First Amendment rights of:

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Plaintiff; other publishers and correspondents who wish to send books, magazines,

20

other publications, legal materials, or other mail to prisoners confined at the Walla

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Walla County Jail; and prisoners at the Jail.
4.40 Defendants’ written and unwritten policies, practices, customs, or

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23

usages unconstitutionally burden and interfere with the Fourteenth Amendment

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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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due process rights of Plaintiff, other publishers and correspondents, and prisoners

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at the Walla Walla County Jail, whose publications and other mail has been or will

3

be rejected by Defendants without notice of the reasons or an opportunity to be

4

heard to challenge Defendants’ censorship decisions.

5

4.41 Defendants’ written and unwritten policies, practices, customs, or

6

usages described above constitute a prior restraint on speech in violation of the

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First Amendment.
4.42 Defendants’ written and unwritten polices, practices, customs, or

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9

usages have violated, continue to violate, and are reasonably expected to violate in

10

the future Plaintiff’s constitutional rights to distribute its publications,

11

communicate its political message to prisoners, recruit new supporters, readers and

12

subscribers, and have caused Plaintiff additional financial harm in the form of lost

13

subscriptions, and publication and book purchases.
V.

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Violation of First Amendment to U.S. Constitution

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5.1

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CAUSES OF ACTION

Plaintiff alleges and incorporates by reference the preceding

paragraphs.
5.2

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Through the acts and failures to act described above, Defendants have

19

violated Plaintiff’s rights, the rights of other publishers and correspondents, and the

20

rights of prisoners confined at the Walla Walla County Jail under the First

21

Amendment to the United States Constitution through 42 U.S.C. § 1983.
5.3

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23

The acts described above have caused Plaintiff damages and will

continue to cause damage.

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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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5.5

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Plaintiff seeks declaratory and injunctive relief against all Defendants

in their official capacities.
Violation of Fourteenth Amendment to U.S. Constitution
5.6

6

Plaintiff realleges and incorporates by reference the preceding

paragraphs.
5.7

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PageID.15

Plaintiff seeks nominal, compensatory, and punitive damages against

5

7

filed 11/25/25

Defendants in their individual capacities.

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4

ECF No. 1

Through the acts and failures to act described above, Defendants

violated Plaintiff’s rights, the rights of other publishers and correspondents, and the

10

rights of prisoners confined at the Walla Walla County Jail under the Fourteenth

11

Amendment to the United States Constitution through 42 U.S.C. § 1983.
5.8

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continue to cause damage.
5.9

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15

Plaintiff seeks nominal, compensatory, and punitive damages against

Defendants in their individual capacities.
5.10 Plaintiff seeks declaratory and injunctive relief against all Defendants

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17

The acts described above have caused Plaintiff damages and will

in their official capacities.
Monell Claim Against the Municipal Defendant

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5.11 Plaintiff realleges and incorporates by reference the preceding

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20

paragraphs.

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5.12 The officials or employees named above acted under color of state

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law and their acts deprived Plaintiff of its constitutional right to free speech and

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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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due process, and in doing so acted pursuant to an official policy or widespread and

2

longstanding practice or custom of the municipal Defendant, Walla Walla County.
5.13 The municipal defendant is liable to Plaintiff by virtue of its

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4

unconstitutional implementation of its policies, practices, customs, or usages,

5

which were the motivating factor and proximate cause of the harm to Plaintiff’s

6

constitutional rights.
5.14 The acts described above have caused damages to Plaintiff and will

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8

continue to cause damage.
5.15 Plaintiff seeks nominal and compensatory damages against the

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10

municipal Defendant.
5.16 Plaintiff seeks declaratory and injunctive relief against the municipal

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12

Defendant.
VI.

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6.1

14

INJUNCTION ALLEGATIONS

Defendants’ unconstitutional policy, practices, customs, and usages

15

are ongoing and continue to violate Plaintiff’s constitutional rights and the rights of

16

other publishers, correspondents, and prisoners, and as such there is no adequate

17

remedy at law.

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6.2

Plaintiff seeks injunctive relief prohibiting Defendants from: refusing

19

to deliver or allow delivery of books, magazines, correspondence, or any other

20

documents from Plaintiff that contain third-party legal material addressed to and

21

intended to be received by specific prisoners at the Walla Walla County Jail;

22

rejecting publications or other documents sent to prisoners at the Walla Walla

23

County Jail pursuant to their publication ban; and censoring or rejecting

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MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

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publications or other documents sent to prisoners at the Walla Walla County Jail

2

on the same grounds that Defendants rejected Plaintiff’s mail. Plaintiff also seeks

3

an injunction prohibiting Defendants from censoring or rejecting mail without due

4

process of law.
VII.

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REQUEST FOR RELIEF

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WHEREFORE, Plaintiff requests relief against Defendants as follows:

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7.1 A preliminary and permanent injunction preventing Defendants from

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continuing to violate the Constitution, and providing other equitable relief;

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7.2 A declaration that Defendants’ implementation of their policies,

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practices, customs, or usages violates the Constitution;

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7.3 For each violation of its Constitutional rights, nominal and

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compensatory damages against the individual Defendants in their individual

13

capacity and against the municipal Defendant, in an amount to be proved at trial;

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7.4 For each violation of its Constitutional rights, punitive damages against

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the individual Defendants in their individual capacity, in an amount to be proved at

16

trial;

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7.5 A trial by jury;

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7.6 Costs and reasonable attorney’s fees, under 42 U.S.C. § 1988, and

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under other applicable law;

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7.7 Pre-judgment and post-judgment interest;

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7.8 The right to conform the pleadings to the proof and evidence presented

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at trial; and
7.9 Such other relief as the Court deems just and equitable.

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COMPLAINT - 17
sk212201

MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961

Case 4:25-cv-05162

ECF No. 1

filed 11/25/25

PageID.18

Page 18 of 18

DATED this 24th day of November, 2025.

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2

MacDONALD HOAGUE & BAYLESS

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By: /s/ Katherine C. Chamberlain
Katherine C. Chamberlain, WSBA #
40014
katherinec@mhb.com
705 Second Avenue, Suite 1500
Seattle, WA 98104
206-622-1604

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5
6
7
8

MacDONALD HOAGUE & BAYLESS

9
10

By: /s/ Jesse Wing
Jesse Wing, WSBA #27751
jessew@mhb.com
705 Second Avenue, Suite 1500
Seattle, WA 98104
206-622-1604

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12
13
14

HUMAN RIGHTS DEFENSE CENTER

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By: /s/ Jonathan P. Picard
Jonathan P. Picard, Fla. Bar # 105477*
jpicard@humanrightsdefensecenter.org
P.O. Box 1151
Lake Worth, FL 33460
561-360-2523

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*Pro hac vice application to be filed

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21
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23

COMPLAINT - 18
sk212201

MACDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, Washington 98104
Tel 206.622.1604 Fax 206.343.3961