MATTER OF GRIFFIN v. Coughlin
88 N.Y.2d 674, 649 N.Y.S.2d 903, 673 N.E.2d 98 (1996)
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Rule of Law:
Under the Establishment Clause of the First Amendment, a state correctional facility cannot deprive an atheist or agnostic inmate of eligibility for expanded family visitation privileges for refusing to participate in a mandatory addiction program that primarily incorporates religious practices and precepts of Alcoholics Anonymous, without offering a secular alternative. Such state-compelled participation constitutes an unconstitutional endorsement of religion and coercion of religious exercise.
Facts:
- Petitioner, an inmate, was serving a sentence of imprisonment in the State correctional system.
- Prior to May 1991, petitioner had been approved for participation in the Family Reunion Program.
- In May 1991, petitioner was transferred to the Shawangunk Correctional Facility.
- Upon arrival at Shawangunk, petitioner was told that his continued eligibility for the Family Reunion Program was contingent on his participation in the ASAT Program because his criminal history revealed heroin use between 1955 and 1968.
- Petitioner had a long-time documented history of having declared himself an atheist or agnostic to correctional authorities.
- After several months of attending the ASAT Program, petitioner submitted a grievance complaining that the program was based on religious principles embodied in the 'Twelve Steps' and 'Twelve Traditions' of Alcoholics Anonymous (A.A.), thereby violating the First Amendment.
- Respondents conceded that a major emphasis of the ASAT Program was inmate participation in self-help groups conducted by A.A. or Narcotics Anonymous (N.A.) volunteers, fully employing the A.A. meeting methodology based on the Twelve Steps.
Procedural Posture:
- Petitioner submitted a grievance to the Shawangunk Correctional Facility requesting to be excused from the ASAT Program without forfeiting his Family Reunion Program eligibility.
- The facility's grievance committee initially responded that no secular alternative substance abuse program was offered and subsequently denied the grievance.
- Petitioner exhausted all administrative opportunities for relief within the correctional system.
- Petitioner brought a CPLR article 78 proceeding in the New York Supreme Court (trial court) seeking a judgment to annul the determination and require respondents to discontinue the attendance requirement.
- The Supreme Court dismissed the petition.
- Petitioner appealed to the Appellate Division (intermediate appellate court).
- The Appellate Division affirmed the Supreme Court's dismissal, concluding that the A.A. component was not a religious exercise.
- Petitioner was granted leave to appeal to the New York Court of Appeals (highest court).
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Issue:
Does a State correctional facility violate the Establishment Clause of the First Amendment by conditioning an atheist or agnostic inmate's eligibility for expanded family visitation privileges on his mandatory participation in the facility's sole alcohol and drug addiction treatment program, which heavily incorporates the religiously-oriented Twelve Steps of Alcoholics Anonymous without offering a secular alternative?
Opinions:
Majority - Levine, J.
Yes, a State correctional facility violates the Establishment Clause of the First Amendment by conditioning an atheist or agnostic inmate's eligibility for expanded family visitation privileges on his mandatory participation in the facility's sole alcohol and drug addiction treatment program, which heavily incorporates the religiously-oriented Twelve Steps of Alcoholics Anonymous without offering a secular alternative. The court found that a fair reading of the fundamental A.A. doctrinal writings, particularly the 'Twelve Steps,' reveals a dominant and unequivocally religious theme, explicitly referring to 'God' as a Supreme Being, Creator, and Father of Light, and requiring prayer, confession of wrongs, and seeking 'His Will.' These expressions and practices, the court held, constitute religious exercise for Establishment Clause purposes. The State, through its correctional authorities, exercised coercive power by denying eligibility for the Family Reunion Program to inmates who refused to participate in this religious activity, especially since no secular drug and alcohol addiction treatment program was offered as an alternative. This coercion violated the principle that the state cannot force an individual to profess a religious belief or participate in a religious activity, as established in cases like Everson v. Board of Educ. and Lee v. Weisman. Furthermore, the mandatory, exclusive ASAT Program failed the 'primary effect' prong of the Lemon test by endorsing and advancing religion, as inmates in the inherently authoritarian atmosphere of a prison would perceive the program as favoring adherents to those beliefs. The court clarified that its ruling did not denigrate A.A.'s effectiveness or prohibit voluntary participation, but specifically targeted the coercive, state-mandated nature of the program without a secular alternative.
Dissenting - Bellacosa, J.
No, the State correctional facility does not violate the Establishment Clause. The dissent argued that the ASAT Program, including its A.A. component, does not breach constitutional boundaries because A.A. is overwhelmingly secular in its philosophy, objective, and operation, focusing on self-help and sobriety rather than promoting a specific religion. While A.A. literature contains 'deistic symbols and allusions,' these reflect 'spiritually accented landscape' but not a 'constitutionally objectionable religious core.' The dissent emphasized that the court should not take an 'absolutist approach' to the Establishment Clause, as incidental advancement of religion can occur without violating the Constitution. It pointed to A.A.'s 'Twelve Traditions' which explicitly declare against sectarian preference or promotion. The dissent disagreed with the majority's reliance on a 'dominant coercion element,' asserting that coercion is not a necessary element of an Establishment Clause claim and that the prison context allows for limitations on inmates' rights, as noted in O’Lone v. Estate of Shabazz. Petitioner, the dissent argued, voluntarily chose to participate in the discretionary Family Reunion Program, which had conditions, and was not truly 'compelled' in a constitutional sense. The analogy to mandatory school prayer cases (Lee v. Weisman, Engel v. Vitale) was deemed inapposite because they involve children and formal prayer, distinct from A.A. participation for adults in a prison setting. The dissent concluded that the ASAT Program had a secular purpose (treating substance abuse), its primary effect was not to advance religion, and it did not foster excessive entanglement, thus satisfying the Lemon test.
Analysis:
This case significantly clarifies the application of the Establishment Clause within the unique context of state correctional facilities, particularly regarding rehabilitation programs. It underscores that even widely recognized and effective programs, such as those based on A.A.'s Twelve Steps, can violate constitutional guarantees if they are mandated by the state without a secular alternative, especially when eligibility for privileges is contingent upon participation. The decision reinforces the judiciary's role in safeguarding individual religious freedom and conscience against governmental pressure, even for incarcerated individuals, and mandates that states must offer secular alternatives for programs with religious content if participation is compulsory.
