Two inmates housed in Robertson County, Tennessee, failed to state a religious liberty claim over the fact that their religious services took place in their housing pod that was noisy with the television blaring too loudly, a federal district court judge has ruled.
The case shows that before inmates can advance a cognizable religious liberty claim under the Free Exercise Clause or the Religious Land Use Institutionalized Persons Act (RLUIPA), they must show that the practice imposes a substantial burden on their religious exercises.
Ronald Allen and Ezra Jones, both inmates in Robertson County, filed a civil rights claim, alleging a variety of claims. One of those claims concerned religious liberty. Allen and Jones claimed their rights to religious liberty were violated, because their church services were not quiet enough.
Every week or two, a chaplain would come to their housing pod and hold prayer services. However, other inmates were out of their cells, acted disrespectfully, and turned the television on too loudly. The plaintiffs alleged “this is no way what I consider having church.”
However, U.S. District Court Judge Aleta A. Trauger for the Middle District of Tennessee dismissed their religious-liberty claims, finding that the plaintiffs failed to allege that the excess noise imposed a “substantial burden” on their ability to practice religion.
Under both the Free Exercise clause of the First Amendment and the statute RLUIPA, prisoners possess the right to religious liberty. However, a violation under either the First Amendment or RLUIPA does not occur unless the plaintiff shows that the governmental practice, rule, or inaction imposes a “substantial burden” on the plaintiffs’ ability to practice their religion.
“The plaintiffs fail to allege facts demonstrating that worshipping in isolation and silence is a central religious belief or practice,” Traugher wrote in her April 5, 2018, decision in Jones v. Holt.
“Although plaintiffs may prefer to have a silent, dedicated space in which to practice their faith, the facts that they have alleged fail to show or support a reasonable inference that noise from the television and other inmates imposes a substantial burden on their ability to exercise their religion.”
While the plaintiffs’ religious liberty claim failed, Traugher allowed their Eighth Amendment claim to proceed based on prison officials’ failure to provide any outdoor recreation time. The Eighth Amendment prohibits cruel and unusual punishment by government officials. Courts have held that prisoners must receive some outdoor time during their incarceration.