Establishment Claims At Hawaii Youth Correctional Facility Not Proven

In R.G. v. Koller, 2006 U.S. Dist. LEXIS 24968 (D Haw., Feb. 7, 2006), a Hawaii federal district court refused to grant a preliminary injunction in a suit by teenagers confined at the Hawaiian Youth Correctional Facility who claimed that HYCF violated the Establishment Clause. Plaintiffs alleged that HYCF endorsed religion by allowing the wards to keep only Bibles and no other personal belongings or books in their cells. They also claimed that certain HYCF staff members promoted religion, often discussing religious teachings and quoting from the Bible, and that HYCF ratified the conduct of these staff members. The Court found that the evidence was not sufficient to support these claims. The court did, however, preliminarily enjoin various other practices at HYCF, finding them to be a violation of the due process clause.