Green Haven Prison Preparative Meeting v. New York State Dept. of Corrections, No. 20-18 (2d Cir. 2021)Annotate this Case
The Second Circuit affirmed the district court's denial of plaintiffs' motion for a preliminary injunction directing defendant officials of the DOCCS to rescind changes in the scheduling of certain regularly-held Quaker religious gatherings at Green Haven Correctional Facility. The court agreed with the district court that a preliminary injunction is not warranted because plaintiffs are 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 court 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 have established that any violation of their religious liberties would satisfy the irreparable injury standard. However, the court 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 defendants' contention that plaintiffs failed to clearly establish that defendants' actions concerning Quarterly Meetings substantially burden plaintiffs' exercise of religion since defendants rescheduled the meetings for Friday evenings and did not terminate them. Furthermore, the record reinforces the district court's conclusion that defendants' rescheduling decision was supported by legitimate concerns. Finally, the court concluded that the balance of equities and the public interest do not tip in favor of granting a preliminary injunction.