Court: Prison Officials Must Justify Religion Policies
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A federal appeals court in Manhattan has ruled in favor of a Sunni Muslim prison inmate who said his First Amendment rights were violated when correctional officers required Sunni and Shiite inmates to pray together.
The recent ruling by the 2nd U.S. Circuit Court of Appeals reverses a lower court’s ruling and gives new life to a First Amendment lawsuit challenging other decisions of the correctional officers responsible for the inmate.
The ruling suggests that prison officials are not entitled to the benefit of the doubt when inmates challenge policies that limit their access to religious services or meals. The decision says prison officials have the burden of justifying their policies before it comes to the point of a judge dismissing a lawsuit.
The decision shows that prison officials cannot “do pretty much whatever they want in curtailing an inmate’s freedom,” the attorney for the inmate, Jon Romberg, a professor at Seton Hall University, said. Instead, prison officials must make a showing that they are acting for “penological reasons,” he said.
The inmate who filed the suit, Abdullah Salahuddin, 54, is serving a murder sentence of 25 years to life. The legal claims from Salahuddin’s 2002 lawsuit come from policies at three different correctional centers he stayed in between 2000 and 2001.
While at the Woodbourne Correctional Facility, in 2000, Salahuddin, a Sunni Muslim, claimed a decision to have Shiite and Sunni inmates conduct joint Ramadan services violated his religious freedoms. Salahuddin had an objection to prison policies regarding the following Ramadan, which he observed while at the Attica Correctional Facility. There, Salahuddin said a prison official forced him to choose between Ramadan services or studying in the law library, but did not allow him to do both in a given day. While housed in restrictive and isolating conditions in a third facility, Salahuddin claimed prison officials were wrong to deny him religious meals in his cell.
A U.S. district judge, Charles Brieant, dismissed the suit in 2005.
The decision by a three-judge panel for the 2nd Circuit expressed concern that Judge Brieant had thrown out the claims without requiring prison officials to justify the policies. The decision suggests that at least some of the prison policies are defensible.
The decision points out that the prison can cite a shortage of space to justify joint Ramadan services. But the 2nd Circuit seems more critical of the decision by prison officials to withhold religious meals from Salahuddin while he was being held in disciplinary keeplock.
A spokesman for the office of the attorney general, which is defending the prison officials, declined to comment on the ruling.
Judge John Walker wrote the decision, which judges Amalya Kearse and J. Clifford Wallace signed.