163682P.pdf   01/02/2018  Cheryl Simpson  v.  County of Cape Girardeau
   U.S. Court of Appeals Case No:  16-3682
   U.S. District Court for the Eastern District of Missouri - Cape Girardeau   
   [PUBLISHED] [Shepherd, Author, with Loken and Arnold, Circuit Judges] 
   Civil case - Civil rights. In suit challenging jail's policy of 
   restricting incoming non-privileged mail to postcards, the district 
   court's decision to exclude evidence of other institutions' mail policies, 
   if error, was harmless error as the court had evidence of the jail's prior 
   policies as an example of an alternative policy; the postcard-only policy 
   was rationally related to the legitimate penological interests of an 
   efficiently run and secure institution; alternative means of communication 
   were available and the policy did not limit the number of cards plaintiff 
   could send; accommodating plaintiff's demands would cause a significant 
   reallocation of the jail's resources and interfere with its ability to 
   maintain institutional security and efficiency; the cost of returning to 
   the jail's old policy or some other policy would be more than de minimis; 
   since all of the relevant factors favor the jail, the policy is 
   constitutional.