O'lone v. Estate Of Shabazz

PETITIONER: Edward O'Lone
RESPONDENT: Estate of Ahmad Uthman Shabazz and Sadr-Ud-Din Nafis Mateen
LOCATION: Leesburg (Bayside) State Prison

DOCKET NO.: 85-1722
DECIDED BY: Rehnquist Court (1986-1987)
LOWER COURT: United States Court of Appeals for the Third Circuit

CITATION: 482 US 342 (1987)
ARGUED: Mar 24, 1987
DECIDED: Jun 09, 1987

ADVOCATES:
James Katz - on behalf of the respondents
Laurie M. Hodian - on behalf of the petitioners
Roger Clegg - amicus curiae, supporting petitioners

Facts of the case

Ahmad Uthman Shabazz and Sadr-Ud-Din Nafis Mateen were inmates in New Jersey’s Leesburg State Prison. The prison classified inmates depending on the security risk each posed. Due to their classification, Shabazz and Mateen were assigned to a prison job outside of the main prison building and were not allowed to return to the main prison building during the workday. Because of these restrictions neither men, both of whom were practicing Muslims, were able to attend Juamu’ah, a weekly religious service held on Fridays.

The two men sued the prison and argued that the work policies infringed on their First Amendment rights to free exercise of religion. The federal district court found in favor of the prison and held that the prison policies plausibly advanced the goals of security, order, and rehabilitation. The U.S. Court of Appeals for the Third Circuit reversed the lower court’s ruling and held that the prison was required to show that there was no other reasonable method by which the inmate’s religious rights could be accommodated without creating actual security problems.

 

Question

If a prison policy infringes on inmates’ free exercise of religion, must the prison show that there are no reasonable alternatives that would accomplish the same goal without creating an actual security issue?

Media for O'lone v. Estate Of Shabazz

Audio Transcription for Oral Argument - March 24, 1987 in O'lone v. Estate Of Shabazz

William H. Rehnquist:

We will now hear argument No. 85-1722, Edward O'Lone versus the Estate of Ahmad Uthman Shabazz and another respondent.

Ms. Hodian, you may proceed whenever you're ready.

Laurie M. Hodian:

Mr. Chief Justice and may it please the Court.

The issue presented here is the standard of review of a prison regulation which affects the ability of some prisoners to participate in a religious practice.

The case is here on a writ of certiorari to the Court of Appeals for the Third Circuit.

The regulation at issue required prison inmates who are assigned to work outside during the day to remain outside.

It prohibited returns to the institution for any reason, save for medical emergencies.

The District Court upheld the regulation against Respondent's First Amendment challenge, finding that it was reasonably related to legitimate goals of security and rehabilitation, and that it was not an exaggerated response to those objectives.

A panel from the Court of Appeals decided the case under its St. Claire versus Cuyler standard, a reasonable relationship tests.

A rehearing en banc was then granted, and the Court of Appeals modified its earlier test, holding that prison officials must prove their regulations are intended to serve and do serve security goals.

And, further, they must prove that there is no reasonable method in existence to accommodate the inmates' religious practices without creating bona fide security problems.

Petitioners submit that the proper analysis to be applied here is the analysis that was applied by this Court in Jones, Pell versus Procunier and Bell versus Wolfish; that is, a regulation must be reasonably related to a legitimate penalogical objective.

Absent evidence that the response is an exaggerated one, the regulation will be upheld.

William H. Rehnquist:

Ms. Hodian, was the Third Circuit's new test in this case applicable just to free exercise of religion claims on behalf of the prisoners, or was it across the board; do you know?

Laurie M. Hodian:

Of course, only a free exercise claim was raised here.

It's unclear whether it would apply to other First Amendment claims.

This Court has recognized the importance of deferring to the considered judgments that prison officials have to make on a daily basis in regards to questions of security.

Prisons, of course, differ greatly from the outside world.

There really is no counterpart to a prison in the outside world.

They are closed, sub-societies, populated by people who have committed crimes against society and often these are very violent crimes.

Of course, they are involuntarily confined; and that, in and of itself, lends itself to great confrontation and tension between the inmates and staff.

In this hostile, adversarial atmosphere prison officials are charged with maintaining security, maintaining an orderly operation; and to the extent possible prison officials have the obligation to attempt to rehabilitate inmates.

However, inmates are constantly making challenges to prison authority.

The tensions between inmates and staff make for a very volatile atmosphere, and this atmosphere changes at all times.

Sometimes an institution is running very smoothly, and the superintendent may be able to make further privileges available to inmates.

Other times the superintendent will get a sense that there is a great amount of tension underlying the prison administration.

The Court has said that prisoners' claims must be decided against this background.

They must be analyzed in terms of the needs and the problems that confront prison administrators.

In Jones, therefore, this Court held that the burden is not on prison officials to show affirmatively that the regulated activity would be detrimental to proper institutional goals.

Deference is to be extended to their opinions unless there is substantial evidence on the record to show that their response is exaggerated.