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When does a prison need to accommodate the right to practice religion in prison? Where do courts draw the line? The Eighth Circuit addressed this question in a decision involving dietary requests and the doctrine of qualified immunity.
So were the First Amendment rights of prisoner Charles E. Sisney violated when he was denied the right to eat his meals in accordance with his Jewish traditions?
According to a March 19 opinion of the Eighth Circuit Court of Appeals, the prisoner's First Amendment free exercise rights were not violated. As such, the Eighth Circuit affirmed the decision of the district court, where the district court entered a summary judgment on the prisoner's pleas for compensatory damages.
Sisney, a prisoner at the South Dakota State penitentiary, filed a lawsuit in 2003 against prison officials. He claimed that he was denied a request to erect and eat his meals within a succah, a three-sided tent used during the Jewish festival of Sukkot. He sought to have the succah set up in the prison recreation yard. He sued the officers individually, seeking to collect monetary damages.
According to prison regulations, inmates were required to obtain approval of religious activity requests through an application process. Sisney submitted the request, specifying that the succah was to be donated to him from inmates from another prison. His request was denied on the grounds that the prison did not allow inmate-to-inmate transfers and that the succah posed safety risks.
The district court granted a summary judgment motion based on the merits and qualified immunity. Under Section 1997e(e) of the Prison Litigation Reform Act, the court held that there can be no compensatory damages where the free exercise claims contain no allegation of physical injury.
Furthermore, defendants were entitled to qualified immunity on plaintiff's First Amendment free exercise rights claims. The court looked at whether the facts alleged by Sisney made out a violation of a constitutional right and whether the right violated was clearly established at the time of the prison officials' alleged misconduct.
As it was not apparent that a prison inmate's right to reasonable dietary and meal accommodations extended to the level of erecting a succah, the Eighth Circuit held in favor of the prison officials. Furthermore, the court held that prison officials did not have fair notice that it would be unlawful to deny the prisoner's applications. The court essentially found that Sisney failed to present any similar case which indicated that a reasonable prison official would have understood that a denial of the use of a succah violated the prisoner's First Amendment rights to free exercise.
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