Challenge To Prison Limit On Religious Items Partly Successful

In Roy v. Arizona, 2006 U.S. Dist. LEXIS 1488 (D. Ariz., Jan. 13, 2006), an inmate who was an "Occultist/Esoteric Christian" challenged various restrctions on the practice of religion imposed on inmates by the Arizona Department of Corrections. Prisoners were limited to possessing religious items that could fit into a box of a specified size. This restriction was justified by the limited size of cells, the need to minimize friction between cellmates on over-crowding of the cell, the fact that random searches become more complicated as possessions increase, and the need to comply with fire codes. Religious books must be obtained either from the inmate store or directly from the publisher, in order to minimize the introduction of contraband into the prison. Inmates may keep additional books in storage, and may access those books upon request. The court granted the state's request for summary judgment on most of the claims, but permitted plaintiff prisoner to move ahead with his claim that he was improperly denied permission to posses seven requested religious items.