Tuesday, May 10, 2016

Pro se inmate wins constitutional argument on appeal

This pro se inmate wins his case against the State of New York, convincing the Second Circuit to reinstate his religious freedom case.

The case is Williams v. John Doe, a summary order decided on May 6. Plaintiff is in the slammer. He says the jail's food practices violate his religious freedom under the First Amendment. When a case is filed, the judge may dismiss it out of hand if it does not plausibly assert any claims. So the bar is low, but it's also high, because plausibility may be in the eye of the beholder. That's what the Court of Appeals is for.

These cases require proof that a government entity's practices substantially burden your religious beliefs. Although the public may not like this, inmates have religious rights under the First Amendment. In setting up the holding, the Second Circuit (Hall, Calabresi and Walker) says "We have reasoned that when determining whether a prisoner’s religious beliefs have been substantially burdened, the relevant question is whether the infringed-upon religious activity is considered central or important to the prisoner’s practice of his religion." Here's the analysis:

Here, Williams’s complaint alleged that the premature sunset meals forced him to either forego his meal or break his fast; he characterized fasting for Ramadan as important to his practice of Islam and stated that eating before sunset was a “grave spiritual sin” that canceled the “validity” of fasting. Consequently, Williams successfully alleged a plausible free exercise claim.

In rejecting the claim, the district court relied on non-binding case law that says plaintiff suffered a trivial burden because only a few of his meals were delivered prematurely. But that case law runs afoul of Second Circuit precedent, which cautions against "the danger that courts will make conclusory judgments about the unimportance of the religious practice" to the plaintiff.

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