Isaac Felton v. Sammy Joseph

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted November 13, 2025*
Decided November 14, 2025
Before
MICHAEL B. BRENNAN, Chief Judge
DIANE S. SYKES, Circuit Judge
AMY J. ST. EVE, Circuit Judge
No. 25-1599
ISAAC FELTON,
Plaintiff-Appellant,
v.
SAMMY JOSEPH,
Defendant-Appellee.
Appeal from the United States District
Court for the Southern District of
Indiana, Indianapolis Division.
No. 1:22-cv-02133-JRS-KMB
James R. Sweeney II,
Judge.
O R D E R
Isaac Felton, an Indiana prisoner, appeals the dismissal of claims arising from his
designation as a member of a security-threat group. He contends that the designation
violated his First Amendment right to freedom of expression and Fourteenth
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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Amendment right to due process. Because the security-threat designation is reasonably
related to a legitimate penological interest and Felton lacks a protected liberty interest
in prison programs, we affirm the judgment.
Fans of the music group Insane Clown Posse commonly refer to themselves as
“Juggalos.” Felton is incarcerated at New Castle Correctional Facility, in New Castle,
Indiana, and is a fan of Insane Clown Posse who identifies as a Juggalo and has
multiple tattoos to show for it. In 2011 the FBI classified Juggalos as a “loosely-
organized hybrid gang,” and following this lead, prison officials, including those at
New Castle, have identified Juggalos as a “security threat group.” Felton alleges that
because of his status as a member of a security-threat group, he is excluded from certain
programs, including a mental-health program, that could help him earn good-time
credits. He further states that other inmates have harassed him because of his security-
threat designation. Felton alleges that he reported these issues to Sammy Joseph, head
of internal affairs at New Castle, but Joseph upheld his classification.
Felton sued Joseph, several higher-level officials within the Indiana Department
of Corrections, and two program managers at New Castle. At screening, see 28 U.S.C.
§ 1915A, the district judge concluded that Felton failed to state a claim under the First
Amendment based on his freedom to express his appreciation for Insane Clown Posse’s
music. The judge determined that prison officials’ labeling Juggalos as a security-threat
group was consistent with the FBI’s report and rationally related to prison security. The
judge further rejected a due-process claim because he concluded Felton did not have a
protected liberty interest in the prison programs from which he was excluded. The
judge allowed Felton to amend his complaint, and Felton did so, this time naming only
Joseph and the New Castle program managers. The judge again dismissed any First
Amendment claim but permitted Felton to proceed on a “class-of-one” claim under the
Equal Protection Clause against Joseph—on the theory that only a subset of Juggalos
were labeled as threats. Eventually, the judge granted Joseph’s motion for summary
judgment and entered final judgment, leading to this appeal.
On appeal Felton challenges only the screening orders. We review the dismissal
of these claims de novo, taking Felton’s allegations as true. Gomez v. Randle, 680 F.3d
859, 864 (7th Cir. 2012). Felton argues that the district judge wrongly deferred to the
prison’s determination that Juggalos were a security-threat group under Turner v. Safley,
482 U.S. 78 (1987). Under Turner, a prison regulation is a valid restraint on a prisoner’s
constitutional rights if it is reasonably related to legitimate penological interests. Id.
at 89. We have extended the Turner framework to resolve whether prison officials have

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unlawfully deprived a prisoner of benefits because of his protected speech. See Bridges v.
Gilbert, 557 F.3d 541, 551 (7th Cir. 2009). Dismissal under § 1915A is appropriate when
the complaint reveals the prison’s legitimate interest and the bridge between that
interest and the restriction. See Munson v. Gaetz, 673 F.3d 630, 634 (7th Cir. 2012).
Even if we accept that Felton’s tattoos and his identification as a Juggalo are
speech or implicate associational rights under the First Amendment, he fails to state a
claim that this expression is protected under Turner. Several factors are relevant in
reaching this determination, including whether there is a connection between
suppression of speech and a valid and neutral government interest and whether there
are alternative means of exercising the constitutional right. Turner, 482 U.S. at 89–90.
Gang suppression is undisputably a legitimate penological interest. Westefer v.
Snyder, 422 F.3d 570, 575 (7th Cir. 2005). It is likewise undisputed that Juggalos were
recognized as a “loosely-organized hybrid gang” according to the FBI’s 2011 report. The
report described hybrid gangs as “difficult to track, identify, and target as they are
transient and continuously evolving.” NAT' L GANG I NTELLIGENCE C TR ., 2011 NATIONAL
GANG THREAT A SSESSMENT – EMERGING TRENDS 22 (2011); Parsons v. U.S. Dep’t of Justice
(Parsons II), 878 F.3d 162, 165 n.1 (6th Cir. 2017). To contest this report, Felton relies on
Parsons v. U.S. Dep’t of Justice (Parsons I), 801 F.3d 701 (6th Cir. 2015), in which the Sixth
Circuit held that Juggalos had standing to challenge their inclusion. But the court
ultimately dismissed the Juggalos’ claims as unreviewable under the Administrative
Procedure Act—thus leaving the Juggalos in the report. Parsons II, 878 F.3d at 171.
Regardless, we have recognized that prison “gang symbolism is not static;
symbols change and are added as gangs expand their bases and combine with other
groups.” Koutnik v. Brown, 456 F.3d 777, 785 (7th Cir. 2006). For this reason, we defer to
prison officials’ expertise in identifying and managing gang-related expression. Id.
Felton cannot overcome this deference merely by observing that not all Juggalos are
violent and asserting that he is among the nonviolent group. Prison officials “need not
wait for a problem to arise before taking steps to minimize security risks,” Hadi v. Horn,
830 F.2d 779, 785 (7th Cir. 1987), and so may take preemptive measures before Felton or
other Juggalos exhibit gang-like activity at New Castle.
The other Turner factors also do not weigh in Felton’s favor. Felton suggests that
prison officials are not acting neutrally because fans of other artists, like Snoop Dogg or
Taylor Swift, are not similarly considered security-threat groups. Even if we assume
that fans of other artists could be but are not designated security-threat groups,

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“inconsistent results are not necessarily signs of arbitrariness or irrationality.” Munson,
673 F.3d at 636 (quoting Thornburgh v. Abbott, 490 U.S. 401, 417 n.15 (1989)). A policy is
“neutral” under Turner if officials draw distinctions between groups “solely on the basis
of their potential implications for prison security.” Thornburgh, 490 U.S. at 415–16.
Prison officials have determined that Juggalos present a greater risk of harm than other
music fans, and we must defer to their expertise. And Felton, like fans of other artists,
still has means to exercise his rights: he attested that he is permitted to listen to Insane
Clown Posse’s music despite the designation.
Felton otherwise contests the process leading to the security-threat group
designation, insisting that the prison never introduced evidence of his relationship to a
criminal organization that is admissible under the Indiana Rules of Evidence. But prison
officials are not bound by the rules of evidence when making decisions about prison
security and discipline. See, e.g., Crawford v. Littlejohn, 963 F.3d 681, 683 (7th Cir. 2020).
Regardless, the judge correctly recognized that Felton fails to state any due-process
claim because he has no protected property or liberty interest in prison programs, even
if they would help him earn good-time credits. Zimmerman v. Tribble, 226 F.3d 568, 571–
72 (7th Cir. 2000).
AFFIRMED

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