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Cruz v. Beto
Citations: 31 L. Ed. 2d 263; 92 S. Ct. 1079; 405 U.S. 319; 1972 U.S. LEXIS 80Docket: 71-5552
Court: Supreme Court of the United States; March 20, 1972; Federal Supreme Court; Federal Appellate Court
The complaint under 42 U.S.C. § 1983 alleges that Cruz, a Buddhist inmate in a Texas prison, faced discrimination as he was not permitted to use the prison chapel, unlike members of other religious sects. Following the sharing of his Buddhist materials with fellow inmates, he was placed in solitary confinement for two weeks on a restricted diet, without access to news sources or the ability to communicate with his religious advisor. The isolation unit imposes 22 hours of idleness each day. Meanwhile, the Texas prison system allegedly promotes participation in Catholic, Jewish, and Protestant religious programs, providing resources and incentives for those faiths, which enhances inmates' eligibility for jobs and parole. The prison administration denied the allegations, seeking dismissal, which the Federal District Court granted without a hearing, suggesting that prison administration has discretion in religious practice management. The Court of Appeals upheld this ruling, emphasizing the need for federal courts to respect the administration's latitude. However, it is acknowledged that prisoners retain the right to petition the government for grievances, including access to courts. The excerpt cites previous cases establishing that racial segregation and religious discrimination are unconstitutional within prisons, barring security necessities. The Court referenced Cooper v. Pate, where allegations of religious discrimination warranted a cause of action. It emphasized that if Cruz's claims of unequal religious opportunity are true, it constitutes discrimination against Buddhism, a religion established over two millennia ago. The First Amendment, through the Fourteenth Amendment, prohibits government interference with the free exercise of religion. Thus, if Cruz's allegations are assumed true, Texas has violated the First and Fourteenth Amendments. The motion for leave to proceed in forma pauperis was granted. The petition for certiorari has been granted, resulting in the vacating of the previous judgment and the remanding of the case for further hearing and findings. Justice Blackmun concurs with this outcome. The amended complaint states that the Plaintiff, an inmate in the Texas Department of Corrections and a member of the Buddhist Churches of America, has faced restrictions while incarcerated, first at the Eastham Unit and later at the Ellis Unit. Numerous prisoners within the system wish to practice Buddhism; however, Defendants have denied them the right to hold religious services or share Buddhist teachings. The Plaintiff has been punished, including a two-week solitary confinement on a bread-and-water diet, for sharing Buddhist materials. Despite requests for the use of prison chapel facilities for Buddhist services, Defendants have consistently denied access while maintaining a religious program that favors Protestant, Jewish, and Roman Catholic faiths. This includes state-sponsored chaplains, distribution of Holy Bibles, and regular religious services and classes for these faiths, as well as records of inmate participation that are used to incentivize religious involvement through merit points. The complaint argues that this exclusion constitutes arbitrary discrimination against Buddhism adherents, violating their constitutional rights to religious freedom and equal protection under the law. The document notes that while not every religious group requires equal facilities, reasonable opportunities must be provided for all prisoners to practice their religion without fear of reprisal.