In this religious freedom case, the Second Circuit rules in favor of an inmate who claims the jail did not accommodate his religious practices in feeding him the wrong food. This ruling draws from a recent Supreme Court decision that expands the rights of inmates who are claiming religious discrimination.
The case is Williams v. Annucci, decided on July 10. Plaintiff is a practicing Nazarite Jew whose faith requires that he consume a grape-free, vegetarian and kosher diet. The Department of Corrections argued in the district court that these religious practices are too expensive and administratively burdensome and that "maintaining the integrity of kosher food at the facility is problematic." Now, I know many people don't care about the religious practices of inmates, and that level of concern is probably tied to the crime the inmate-plaintiff had actually committed. But, in the wake of anti-plaintiff Supreme Court rulings in interpreting the Free Exercise Clause, Congress passed the Religious Land Use and Institutionalized Persons Act of 2000, which makes it difficult for prison authorities to violate religious freedom in the jails and elsewhere.
I will leave it to the sociologists to determine why Congress can pass a law that helps inmates so long as it promotes religious freedom, while standing by why the Supreme Court scales back civil rights in other contexts. It is probably the religion angle. Anyway, in 2015, the Supreme Court ruled in Holt v. Hobbs that RLUIPA claims require the courts to view the government's defenses in these case with skepticism. The government needs a compelling interest to justify rejecting the inmate's religious preferences, as Congress passed RLUIPA "to provide very broad protection for religious liberty." The government must also "justify its conduct by showing not just its general interest, but its particularized interest in burdening the individual plaintiff in the precise way it has chosen."
These legal standards give plaintiff the win. The religious freedom law requires the government incur expenses in its own operations to avoid imposing a substantial burden on religious practices. On this record, the Department of Corrections has not shown "that accommodating Williams would significantly increase costs and administrative burdens." The department has not shown precisely how much these dietary changes for Williams would cost or how they would burden the prisons. And the Court of Appeals (Walker, Pooler and Crawford [D.J.]) rejects the "administrative inconvenience" defense, at least in these cases, because "it is the 'classic rejoinder of bureaucrats throughout history' rejected by the Supreme Court in Holt." The case is therefore remanded to the Northern District of New York for additional factfinding on these issues.