Magistrate Defers To Prison Security Concerns In RLUIPA Case

An extreme example of deference to prison authorities' claims in RLUIPA cases is reflected in a recently available Magistrate's decision, Spratt v. Wall, 2005 U.S. Dist. LEXIS 33266 (D RI, Nov. 21, 2005). A convicted murderer, Wesley Spratt, was a gifted preacher who for seven years had preached on a weekly basis at Christian religious services in his Rhode Island prison's maximum security unit, always under the supervision of prison clergy. Spratt saw this as his calling from God. When the prison administration changed, however, Spratt was prohibited from continuing, and Spratt sued claiming an infringement of his free exercise of religion. Authorities argued that security is threatened whenever inmates are given positions of authority or perceived authority, citing unrest and violence at the prison during the 1970's. Accepting this claim, a federal Magistrate Judge found that there are no less restrictive means available to accomplish the prison system's compelling security interest and recommended that summary judgment be granted to defendants.