## Facts

- Kevin T. Singer, a Wisconsin inmate at Waupun Correctional Institution, possessed numerous Dungeons & Dragons (D&D) publications and wrote a 96-page handwritten D&D campaign manuscript.
- From 2002 to 2004, Singer was permitted to order and possess D&D materials without incident.
- In November 2004, a prison official received an anonymous inmate letter claiming Singer and others were forming a “D&D gang” and recruiting by circulating D&D publications.
- Waupun officials adopted a policy banning D&D and confiscated Singer’s D&D publications and his campaign manuscript from his cell.
- The prison justified the ban on security grounds, asserting that D&D could foster group dynamics resembling gangs, encourage hostility or violence, and intensify escapist or obsessive behavior.
- Singer pursued internal prison remedies seeking return of his materials and relaxation of the ban; he did not obtain relief.
- Singer filed a 42 U.S.C. § 1983 action alleging constitutional violations; the district court entered summary judgment for the prison officials.
- On appeal, Singer challenged only the adverse ruling on his First Amendment claims.

## Issues

1. Whether banning D&D and confiscating D&D-related materials violated an inmate’s First Amendment rights under the standard governing prison regulations that burden constitutional rights.
2. Whether Singer produced evidence sufficient to create a genuine dispute of material fact about the rationality of the prison’s security justification, making summary judgment improper.

## Decision

- The Seventh Circuit affirmed summary judgment for the prison officials.
- Applying Turner v. Safley, the court held the D&D ban and confiscations were reasonably related to legitimate penological interests, principally prison security and gang prevention.
- The court concluded that the record did not show a triable dispute undermining the rational connection between the ban and the asserted security concerns.

## Legal Principles

- A prison regulation that impinges on constitutional rights is valid if it is reasonably related to legitimate penological interests. (Turner v. Safley)
- Turner factors guide the analysis: (1) rational connection to a legitimate interest; (2) alternative means of exercising the right; (3) impact of accommodation on prison staff, inmates, and resources; and (4) absence of obvious, easy alternatives.
- Courts give substantial deference to prison administrators’ security judgments; officials need not wait for actual violence or gang activity before acting.
- At summary judgment, an inmate must do more than offer competing characterizations of the regulated activity as harmless in the general public; the question is whether the prison’s stated security rationale is rational in the prison context.

## Conclusion

The court upheld Waupun’s prohibition on Dungeons & Dragons materials and related confiscations, concluding that the restrictions satisfied Turner because prison officials articulated a rational, security-based justification and Singer failed to raise a genuine dispute requiring trial.


Singer v. Raemisch, 593 F.3d 529 (7th Cir. 2010)