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Keohane, (475) when evaluating whether defendant prison officials were entitled to qualified immunity, the Sixth Circuit remarked that the circuit had not yet "clearly established" that opening or reading legal mail violated "constitutional rights in and of itself." (476) Even so, the court reversed summary judgment for the defendants, concluding it was well-established "that opening/reading inmates' mail in 'arbitrary' or 'capricious' fashion does violate inmates' First Amendment rights." (477) Later, in 2003, in Sallier v.
DUBLIN: A Bunyan; R McGowan, S McMahon, G Hannigan; D Devereux, B Howard, G Seaver (0-1); E O Conghaile, A Elliot; S Carthy (Naomh Mearnog 0-3, 0-1f), G O'Reilly, K Doherty (0-1); C Sallier, K O'Gara (0-1), C Basquel (1-6, 0-3f).
Specific axis values for each guild are: IBG (Insectivorous Bark Gleaner) = -0.578, ILGG (Insectivorous Lower Canopy Gleaner) = -0.101, IGG (Insectivorous Ground Gleaner) = -0.074, OLCGF (Omnivorous Lower Canopy and Ground Forager) = 0.035, OGF (Omnivorous Ground Forager) = 0.044, IUCG (Insectivorous Upper Canopy Gleaner) = 0.408, IAS (Insectivorous Air Sallier) = 0.59