Muslim Prisoner's Free Exercise and Establishment Clause Claims Rejected

In Salahuddin v. Perez , 2006 U.S. Dist. LEXIS 4406 (SDNY, Feb. 2, 2006), a New York federal district court rejected a number of claims by Abdullah Y. Salahuddin, a Muslim inmate at New York’s Fishkill correctional facility. Among the rejected claims was Salahuddin’s allegation that his First Amendment right to the free exercise of religion was infringed by preventing 39 Muslim inmates from attending a January 1998 Eidul Fitr end of Ramadan celebration. The court also rejected Salahuddin’s claim that prison officials violated the Establishment Clause of the First Amendment when they implemented a theological educational program in the prison chaplaincy and educational department instead of through Plaintiff’s prisoner organization. Salahuddin had alleged that the decision resulted in favoring Christianity over Islam. The court held that it need not decide whether placing the educational program under Fishkill's chaplaincy and academic departments passed the Lemon test, because the decision was reasonably related to legitimate penological interests within the meaning of the Supreme Court’s 1987 decision in Turner v. Safley. [Thanks to Scott Idleman via Religionlaw listserv for the information.]