O’Lone v. Estate of Shabazz (1986)

O’Lone v. Estate of Shabazz
No. 85-1722
482 U.S. 342 (1987)
June 9, 1987


Respondents, prison inmates and members of the Islamic faith, brought suit under 42 U.S.C. § 1983 contending that two policies adopted by New Jersey prison officials prevented them from attending Jumu’ah, a Muslim congregational service held on Friday afternoons, and thereby violated their rights under the Free Exercise Clause of the First Amendment. The first such policy, Standard 853, required inmates in respondents’ custody classifications to work outside the buildings in which they were housed and in which Jumu’ah was held, while the second, a policy memorandum, prohibited inmates assigned to outside work from returning to those buildings during the day. The Federal District Court concluded that no constitutional violation had occurred, but the Court of Appeals vacated and remanded, ruling that the prison policies could be sustained only if the State showed that the challenged regulations were intended to and did serve the penological goal of security, and that no reasonable method existed by which prisoners’ religious rights could be accommodated without creating bona fide security problems. The court also held that the expert testimony of prison officials should be given due weight on, but is not dispositive of, the accommodation issue.

Respondents, prison inmates and members of the Islamic faith, brought suit under 42 U.S.C. § 1983 contending that two policies adopted by New Jersey prison officials prevented them from attending Jumu’ah, a Muslim congregational service held on Friday afternoons, and thereby violated their rights under the Free Exercise Clause of the First Amendment. The first such policy, Standard 853, required inmates in respondents’ custody classifications to work outside the buildings in which they were housed and in which Jumu’ah was held, while the second, a policy memorandum, prohibited inmates assigned to outside work from returning to those buildings during the day. The Federal District Court concluded that no constitutional violation had occurred, but the Court of Appeals vacated and remanded, ruling that the prison policies could be sustained only if the State showed that the challenged regulations were intended to and did serve the penological goal of security, and that no reasonable method existed by which prisoners’ religious rights could be accommodated without creating bona fide security problems. The court also held that the expert testimony of prison officials should be given due weight on, but is not dispositive of, the accommodation issue.

[O’Lone v. Estate of Shabazz. No. 85-1722. 482 U.S. 342 (1987). June 9, 1987. Oyez Project, IIT Chicago-Kent College of Law. www.oyez.org. Justia: US Supreme Court Center. http://supreme.justia.com/cases/federal/us/482/342/case.html.]