Sunday, June 24, 2018

Recent Prisoner Free Exercise Cases

In Solton v. Anderson, 2018 U.S. Dist. LEXIS 98239 (D KA, June 12, 2018), a Kansas federal district court concluded that defendants had not improperly denied a Muslim inmate's requests for religious materials and a religious diet.

In Degale v. McDonough, 2018 U.S. Dist. LEXIS 98549 (SD NY, June 12, 2018), a New York federal district court dismissed a Rastafarian inmate's challenge to the requirement for an initial shave of inmates to maintain a record of appearance in case of escape.

In Young v. Chuvalas, 2018 U.S. Dist. LEXIS 99618 (SD OH, June 14, 2018), an Ohio federal district court denied summary judgment to defendants in a suit by a Muslim inmate who claims he was forced to attend a Christian prison ministry event.

In Shepherd v. Smith, 2018 U.S. Dist. LEXIS 100012 (ND NY, June 13, 2018), a New York federal magistrate judge recommended that a Rastafarian inmate be allowed to move ahead with his claims against certain defendants that he did not receive a requested cold alternative diet and that there were no Rastafarian religious services available.

In Kearey v. Collier, 2018 U.S. Dist. LEXIS 99513 (SD TX, June 13, 2018), a Texas federal district court adopted a magistrate's recommendation (2018 U.S. Dist. LEXIS 100014, May 8, 2018) and allowed a Taoist inmate to move ahead against two of the defendants on claims that they were denied access to a package containing eastern religious texts and videotapes; they were not permitted to practice moving meditations and yoga in a group setting; and an outside volunteer was required to supervise moving meditations.

In Greene v. Cabral, 2018 U.S. Dist. LEXIS 100408 (D MA, June 15, 2018), a Massachusetts federal district court dismissed a Jewish inmate's claim that he was not properly served sufficient kosher food and that he was denied the ability to participate in religious services led by a rabbi.

In Smith v. Drawbridge, 2018 U.S. Dist. LEXIS 100044 (WD OK, June 13, 2018), an Oklahoma federal district court adopted a magistrate's recommendation (2018 U.S. Dist. LEXIS 100732, May 22, 2018) and dismissed a Jewish inmate's complaint that numerous of his religious practices were not accommodated, including diet, religious services, religious events and apparel.  Most of his claims were dismissed for failure to exhaust administrative remedies, while his complaint regarding observance of a fast day was found not to have amounted to a substantial burden on his free exercise.

In Parker v. Baldwin, 2018 U.S. Dist. LEXIS 100749 (SD I, June 15, 2018), an Illinois federal district court allowed an inmate to move ahead with his complaint that he was wrongly disciplined for teaching the Asatru faith, holding Asatru services and teaching the runes.

In Rhoden v. Department of State Hospitals, 2018 U.S. Dist. LEXIS 100868 (ED CA, June 15, 2018), a California federal district court adopted a magistrate's recommendation (2018 U.S. Dist. LEXIS 90260, May 30, 2018), and allowed a civil detainee to move ahead on his complaint that for several months he has not been allowed a Catholic Chaplain to conduct prayer services and attend mass.

In Gholston v. Powell, 2018 U.S. Dist. LEXIS 102915 (MD GA, June 20, 2018), a Georgia federal district court adopted a magistrate's recommendation (2018 U.S. Dist. LEXIS 103201, May 25, 2018) and allowed a Muslim inmate to move ahead with his complaint that he was not permitted to grow long hair and a beard.