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Prisoner's $50k Claim for Lack of Religious Prison Meal Denied

By Kelly Cheung on May 24, 2013 | Last updated on March 21, 2019

What will the special of the day today, you ask? Probably something of the meat and potatoes variety, but this was not acceptable to Eric Watkins, former federal prisoner.

Watkins was a participant of a Common Fare religious diet program, but he was not given his religious meal. A vegetarian prison meal would have suited him just fine, but he did not get that either. That evening, he ate nothing.

Watkins believed his constitutional rights were infringed upon by Lieutenant Rogers and wanted $50,000 in damages. How much does it cost to miss just one meal?

Most prison systems in the U.S. make special accommodations for their inmates who have special diets. The U.S. Federal Bureau of Prisons does it differently. They have one-size-fits all prison meals plan called Common Fare. The prison meal attempts to meet the dietary restrictions of all religions. Unfortunately for Watkins, Lt. Rogers was in charge of his dinner that night.

The Tenth Circuit Court of Appeals rejected Watkins' claims that Lt. Rogers violated his First Amendment rights by interfering with his religious practice and Eighth Amendment rights by subjecting him to cruel and unusual punishment. Let's look at each argument.

First Amendment

The court requires a demonstration that Lt. Rogers substantially burdened Watkins' sincerely-held beliefs. Dietary religious restrictions are a recognized part of religious beliefs that cannot be denied. The court, however, finds that Watkins' case is not substantial to demonstrate a First Amendment violation.

It was just one isolated violation. Lt. Rogers and the prison did not have a system or policy of refusing to give out vegetarian or Common Fare meals. For whatever reason, Lt. Rogers just didn't give him what he wanted. The court found no fault on Lt. Rogers that day.

Prisoner complaints of lack of access to their religious or special diets have been sprouting up lately. They complain of lack of kosher diets and some even complain they're sick from soy based foods. The courts have to balance the interests of prisoners' religious beliefs against the prison system's concerns for safety and costs.

Eighth Amendment

Although prison meals are not perfect for every prisoner, according to the Encyclopedia of Prisons and Correctional Facilities, food can't be used as punishment. A meal of just bread and water wouldn't work. The meals have to have some nutritional value. For Watkins' one missed meal, it would have to involve a "wanton and unnecessary infliction of pain, nor may...[it] be grossly disproportionate to the severity of the crime warranting imprisonment."

In other cases, this court and other circuits have not found an Eighth Amendment violation in a denial of a requested religious diet for as long as one week. It didn't find one for Watkins either.

Watkins' case suggests that perhaps if he had been denied his special religious diet for over a week or several weeks, he may have had a stronger case. Having missed just one meal wasn't something to cry over. It certainly wasn't a legitimate claim for $50,000 in damages.

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