Hartmann, et al v. California Dept. of Corrections, et al, No. 11-16008 (9th Cir. 2013)
Annotate this CaseThe CDCR, in an effort to meet the religious exercise needs of prison inmates, maintained paid full-time and part-time chaplain positions of five faiths: Catholic, Jewish, Muslim, Native American, and Protestant (the Policy). Plaintiffs claimed, under 42 U.S.C. 1983, that various entities and individuals violated their federal and state constitutional rights by refusing to hire a paid full-time Wiccan chaplain and by failing to apply neutral criteria in determining whether paid chaplaincy positions were necessary to meet the religious exercise needs of inmates adhering to religions outside the five faiths. Because plaintiffs sufficiently pleaded facts supporting a plausible claim under the Establishment Clause and the California State Constitution, the court reversed and remanded both claims to the district court for further proceedings. The court affirmed the district court's dismissal of plaintiffs' remaining claims.
Court Description: Prisoner Civil Rights. The panel affirmed in part and reversed in part the district court’s Fed. R. Civ. P. 12(b)(6) dismissal of an action brought under 42 U.S.C. § 1983 by California state prisoners alleging that defendants violated their state and federal constitutional rights to exercise their religious beliefs by refusing to hire a paid full-time Wiccan chaplain and by failing to apply neutral criteria in determining whether paid chaplaincy positions are necessary to meet the religious exercise needs of inmates adhering to religions outside the five faiths (Catholic, Jewish, Muslim, Native American and Protestant). Affirming the district court, the panel held that the first amended complaint did not contain sufficient facts to support a cognizable legal theory under the First Amendment’s Free Exercise Clause, stating that the Clause did not require prison administration to provide plaintiffs with more than that which they were currently receiving, such as the services of staff chaplains and a volunteer Wiccan chaplain. The panel also held that plaintiffs failed to support their equal protection claim with facts plausibly showing that the prison administration discriminatorily denied their requests for a paid full-time Wiccan chaplain. The panel further held that plaintiffs’ claim under the Religious Land Use and Institutionalized Persons Act failed sufficiently to allege a substantial burden on their religious exercise. Reversing the district court, the panel held that plaintiffs sufficiently pleaded facts supporting plausible claims under the Establishment Clause and the California State Constitution. The panel determined that accepting plaintiffs’ allegations as true, the prison administration failed to employ any neutral criteria in evaluating whether a growing membership in minority religions warranted a reallocation of resources used in accommodating inmates’ religious exercise needs. The panel remanded both claims to the district court for further proceedings.
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