On October 18, 2021 the United States Court of Appeals, Second Circuit affirmed the district court's denial of prisoners and several unincorporated associations and individual members of the Religious Society of Friends ("Quakers") motion for a preliminary injunction directing prison officials of the DOCCS to rescind changes in the scheduling of certain regularly-held Quaker religious gatherings at Green Haven Correctional Facility.

The Second Circuit agreed with the district court that a preliminary injunction was not warranted because the plaintiffs were unable to demonstrate a likelihood of success on the merits of their claims. After determining that it has jurisdiction to address the merits of the appeal, the Second Circuit concluded that, at least insofar as they challenge substantive restrictions on their ability to conduct religious services and meetings in accordance with their beliefs, plaintiffs had established that any violation of their religious liberties would satisfy the irreparable injury standard.

However, the Second Circuit concluded that the claims of Green Haven Meeting, as well as those of the Incarcerated plaintiffs suing in their own names, must be dismissed for failure to exhaust administrative remedies. In regard to the Non-Incarcerated plaintiffs, the Court concluded that the changes in the times of the Quarterly Meetings, and the eventual cancellation of those meetings, did not infringe their rights under the Free Exercise Clause of the First Amendment.

The court found persuasive the contention that plaintiffs failed to clearly establish that defendants' actions concerning Quarterly Meetings substantially burden their exercise of religion since defendants rescheduled the meetings for Friday evenings and did not terminate them and the record reinforced the district court's conclusion that the defendants' rescheduling decision was supported by "legitimate concerns."

The Court concluded that the Non-Incarcerated Plaintiffs have Article III standing under the US Constitution to challenge the policy changes relating to the Quarterly Meetings, and Green Haven Meeting has Article III standing to challenge all the policy changes.

Second Circuit further held, "the individual Incarcerated Plaintiffs unquestionably have Article III standing to challenge all of the policy changes at issue."

Finally, the court concluded that the balance of equities and the public interest do not tip in favor of granting a preliminary injunction.

For those reasons, the Court agree with the district court that a preliminary injunction was not warranted and affirmed the district court.

Source: Green Haven Prison Preparative Meeting of Religious Soc'y of Friends v. N.Y. State Dep't of Corrs. & Cmty. Supervision, 20-18-pr (2d Cir. Oct. 18, 2021).

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