Prisons; freedom of religion
Where a prison eliminated religious services for a religion, it was error to dismiss a prisoner’s claim alleging that the motivation was hostility to that religion.
“Whether the defendants made reasonable efforts to provide Maddox some opportunity for religious practice or whether they were justified in signaling out AHI services for cancellation because of budgetary restrictions remains to be seen. It is premature to make that determination at the pleading stage. See e.g., Ortiz v. Downey, 561 F.3d 664, 669-70 (7th Cir. 2009) (holding that the district court’s determination at the pleading stage that the prison had a legitimate penological reason to deny detainee religious articles of rosary and prayer booklet was premature); see Alston, 13 F.3d at 1040 (holding dismissal improper where the district court assumed that the defendants were justified in restricting the inmate’s religious freedom because he was in administrative segregation). We do not make any determination about the ultimate merits of the allegations contained in the complaint, nor should our decision today be read as suggesting an outcome. We only conclude that Maddox has stated a claim ‘plausible on its face’ that he was denied a reasonable opportunity to exercise his religion without adequate penological justification.”
Affirmed in part, and Reversed in part.
10-1139 Maddox v. Love
Appeal from the United States District Court for the Southern District of Illinois, Gilbert, J., Tinder, J.