Hamilton v. Schriro

Court of Appeals for the Eighth Circuit
74 F.3d 1545 (1996)

ELI5:

Rule of Law:

Under the Religious Freedom Restoration Act (RFRA), courts must give due deference to the expertise of prison administrators in establishing regulations to maintain institutional safety and security. Even under RFRA's 'least restrictive means' test, prison regulations that burden religious exercise are permissible if they are necessary to further the compelling interest in prison security, particularly when an inmate rejects reasonable, alternative accommodations.

Facts:

Mark Juan Hamilton, an American Indian, is an inmate at Potosi Correctional Center, a maximum-security prison in Missouri.
Hamilton's religious beliefs require him to have long hair, which he believes is a gift from the Creator to be cut only when a close relative dies.
Hamilton's religious beliefs also require participation in a sweat lodge ceremony for purification, which he considers an essential prerequisite for other religious practices.
The sweat lodge ceremony involves a secluded, dome-shaped structure, heated rocks, steam, and tools like an axe and shovel, where participants are nude and cannot be seen from the outside.
The Potosi prison enforces a Missouri Department of Corrections regulation prohibiting male inmates from having hair longer than their collar.
Prison officials required Hamilton to cut his long hair in compliance with this regulation.
The Potosi prison does not allow sweat lodges or sweat lodge ceremonies on its premises, citing safety and security concerns.
Prison officials denied Hamilton's request for access to a sweat lodge ceremony.

Procedural Posture:

Mark Juan Hamilton sued Missouri prison officials in the United States District Court for the Western District of Missouri under 42 U.S.C. § 1983, seeking injunctive relief for violations of his free exercise rights.
After an evidentiary hearing, a magistrate judge, applying the newly enacted Religious Freedom Restoration Act (RFRA), recommended that the district court grant Hamilton's request for an injunction.
The district court adopted the magistrate's recommendation, enjoining prison officials from enforcing the hair length regulation against Hamilton and ordering them to provide a weekly sweat lodge ceremony.
The district court subsequently awarded attorney fees to Hamilton and issued an order detailing the implementation of the sweat lodge ceremony.
The prison officials (appellants) appealed the district court's judgment to the United States Court of Appeals for the Eighth Circuit.

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Issue:

Do a maximum-security prison's regulation requiring short hair and its policy denying access to a sweat lodge ceremony violate an American Indian inmate's right to free exercise of religion under the First Amendment and the Religious Freedom Restoration Act (RFRA)?

Opinions:

Majority - Beam, J.

No, the prison's regulation and policy do not violate the inmate's right to free exercise of religion. Applying RFRA's compelling interest test in the prison context requires giving due deference to the expert judgment of prison administrators regarding institutional security. Both the hair-length regulation and the prohibition on sweat lodges are the least restrictive means of furthering the compelling governmental interest in prison safety and security. Under the First Amendment's 'reasonableness' test established in Turner v. Safley, the regulations are also valid because they are reasonably related to legitimate penological interests. The court found that the security concerns cited by prison officials—such as concealing contraband in long hair, preventing gang identification, and the dangers of unsupervised activities in an enclosed sweat lodge—were valid. The court noted that in the context of RFRA's 'least restrictive means' requirement, deference to prison administrators is still appropriate. Furthermore, Hamilton’s refusal to consider alternative, less restrictive accommodations, such as an outdoor ceremony without an opaque covering, supported the prison's position that a complete prohibition of the sweat lodge was the only viable option to ensure security.

Dissenting - McMillian, J.

Yes, as to the hair length regulation, which would violate the Religious Freedom Restoration Act (RFRA) if the Act were constitutional; however, the dissent's primary conclusion is that RFRA itself is an unconstitutional violation of the separation of powers. The dissent argues that if RFRA were valid, it would restore the pre-O'Lone 'compelling interest' standard, making the court's prior decision in Teterud v. Burns—which struck down a similar hair regulation—controlling precedent and requiring a ruling in Hamilton's favor on that issue. However, the dissent's principal argument is that Congress exceeded its authority under Section 5 of the Fourteenth Amendment by enacting RFRA. In doing so, Congress impermissibly attempted to legislatively overrule the Supreme Court’s interpretation of the Free Exercise Clause in Employment Division v. Smith, thereby defining the substantive scope of a constitutional right, a power reserved for the judiciary. Therefore, the dissent would find RFRA unconstitutional and remand the case for analysis under the pre-RFRA constitutional standard.

Analysis:

This decision significantly interpreted the application of RFRA within the prison context, narrowing its practical effect for inmates. By holding that the 'least restrictive means' test must be applied with 'due deference' to prison officials, the court essentially imported the highly deferential standard of the pre-RFRA Turner test into the RFRA analysis. This precedent made it much more difficult for inmates to win free exercise claims under RFRA, as courts were instructed to defer to prison officials' security justifications. The ruling set a standard that other circuits would grapple with, and the dissent's focus on RFRA's unconstitutionality foreshadowed the Supreme Court's eventual ruling in City of Boerne v. Flores, which struck down RFRA as applied to the states.

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