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Fifth Circuit Upholds Summary Judgment for Jewish Prisoners' Religious Practice
Texas prisoner Thomas H. Baranowski, Pro Se, appealed a summary judgment by the district court. Baranowski, a member of the Jewish faith, alleged that prison officials violated his First and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act (RLUIPA) for not providing weekly Sabbath and other holy day services. He also alleged that Jewish prisoners were not allowed to use the chapel for religious services and were not provided with kosher diets.
Pursuant to 42 U.S.C. §1983, Baranowski filed against employees and official of the Texas Department of Criminal Justice (TDCJ) for declaration and injunctive relief for his claims. He alleged that prison officials treated other religious faiths more favorably than Jewish prisoners by allowing other faiths access to chapel and to observe and practice their faith.
TDCJ officials motioned for summary judgment. Bill Pierce, the Director of the TDCJ Chaplaincy Department, stated that religious services are provided based on demand, need, and resources. Pierce also stated services are nondiscriminatory on offenders' religious beliefs and has to consider space, time, and staffing restraints when addressing the needs of 900 self-described Jewish prisoners out of 145,000 prisoners, 70-75 practicing the Jewish faith. Not all TDCJ units can accommodate services. Pierce stated that the Huntsville hosts weekly Jewish service and that the TDCJ recognized 21 holy days (only two for Christian faith)
The TDCJ is unable to provide kosher diet because it would require remodeling their kitchens and substantially alter food preparation procedures. This would have a financial burden on a budget-strained prison system. The TDCJ has pork-free or vegetarian diet food from meal to meal.
The district court granted the summary judgment because valid penological interest related to prison staffing, space, limitation, and financial burden to accommodate Baranowski's requests and his RLUIPA claims. The Court stated that Baranowski failed to show a deliberate indifference for his discrimination claim.
Baranowski appealed to the Fifth Circuit, which upheld the district court's decision on the First and Fourteenth Amendments based on penological interests and the undue costs and administrative burdens on the prison system. Since he failed to establish the discrimination against him, the Fifth Circuit denied his equal protection claim. Since the TDCJ did not significantly modify his religious behavior or his beliefs, the RLUIPA claim cannot overcome institutional needs to maintain order, security, and control costs.
The Fifth Circuit affirmed the district court grant of summary judgment. See: Baranowski v. Hart, 486 F.3d 112 (5th Cir. 2007).
Pursuant to 42 U.S.C. §1983, Baranowski filed against employees and official of the Texas Department of Criminal Justice (TDCJ) for declaration and injunctive relief for his claims. He alleged that prison officials treated other religious faiths more favorably than Jewish prisoners by allowing other faiths access to chapel and to observe and practice their faith.
TDCJ officials motioned for summary judgment. Bill Pierce, the Director of the TDCJ Chaplaincy Department, stated that religious services are provided based on demand, need, and resources. Pierce also stated services are nondiscriminatory on offenders' religious beliefs and has to consider space, time, and staffing restraints when addressing the needs of 900 self-described Jewish prisoners out of 145,000 prisoners, 70-75 practicing the Jewish faith. Not all TDCJ units can accommodate services. Pierce stated that the Huntsville hosts weekly Jewish service and that the TDCJ recognized 21 holy days (only two for Christian faith)
The TDCJ is unable to provide kosher diet because it would require remodeling their kitchens and substantially alter food preparation procedures. This would have a financial burden on a budget-strained prison system. The TDCJ has pork-free or vegetarian diet food from meal to meal.
The district court granted the summary judgment because valid penological interest related to prison staffing, space, limitation, and financial burden to accommodate Baranowski's requests and his RLUIPA claims. The Court stated that Baranowski failed to show a deliberate indifference for his discrimination claim.
Baranowski appealed to the Fifth Circuit, which upheld the district court's decision on the First and Fourteenth Amendments based on penological interests and the undue costs and administrative burdens on the prison system. Since he failed to establish the discrimination against him, the Fifth Circuit denied his equal protection claim. Since the TDCJ did not significantly modify his religious behavior or his beliefs, the RLUIPA claim cannot overcome institutional needs to maintain order, security, and control costs.
The Fifth Circuit affirmed the district court grant of summary judgment. See: Baranowski v. Hart, 486 F.3d 112 (5th Cir. 2007).
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Related legal case
Baranowski v. Hart
| Year | 2007 |
|---|---|
| Cite | 486 F.3d 112 (5th Cir. 2007) |
| Level | Court of Appeals |