Ramirez v. Collier
595 U. S. ____ (2022)
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Rule of Law:
Under the Religious Land Use and Institutionalized Persons Act (RLUIPA), a state's categorical ban on a spiritual advisor audibly praying or physically touching an inmate in the execution chamber substantially burdens religious exercise and is not the least restrictive means of furthering the state's compelling interests.
Facts:
- In 2004, John Ramirez murdered Pablo Castro during a robbery that netted $1.25.
- A Texas jury convicted Ramirez of capital murder and sentenced him to death.
- Since 2016, Ramirez had been receiving spiritual guidance from Pastor Dana Moore of the Second Baptist Church.
- Texas amended its execution protocol in 2021 to permit a prisoner's chosen spiritual advisor to be present in the execution chamber.
- On June 11, 2021, Ramirez formally requested that his pastor be permitted to 'lay hands' on him and 'pray over' him during his execution, stating this was part of his faith.
- On July 2, 2021, Texas denied the request, stating that spiritual advisors are not allowed to touch an inmate inside the execution chamber.
- After this denial, Ramirez's attorney inquired if Pastor Moore would be allowed to pray audibly during the execution, and prison officials responded that he would not.
Procedural Posture:
- John Ramirez sued Bryan Collier, Executive Director of the Texas Department of Criminal Justice, in the U.S. District Court for the Southern District of Texas.
- Ramirez sought a preliminary injunction to bar his execution unless Texas permitted his pastor to lay hands on him and pray audibly in the execution chamber.
- The District Court denied Ramirez's request for a stay of execution and other injunctive relief.
- Ramirez, as appellant, appealed the denial to the U.S. Court of Appeals for the Fifth Circuit, with Collier as appellee.
- A divided panel of the Fifth Circuit affirmed the District Court's decision, denying relief.
- The U.S. Supreme Court granted a stay of Ramirez's execution and granted his petition for a writ of certiorari.
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Issue:
Does Texas's policy prohibiting a spiritual advisor from audibly praying with and physically touching an inmate in the execution chamber violate the Religious Land Use and Institutionalized Persons Act (RLUIPA)?
Opinions:
Majority - Chief Justice Roberts
Yes, Texas's policy is likely to violate RLUIPA. The Court held that Ramirez is likely to succeed on his RLUIPA claims because Texas’s restrictions on religious touch and audible prayer in the execution chamber impose a substantial burden on his sincere religious exercise and are not the least restrictive means of furthering the State’s compelling interests. The Court found Ramirez's requests for prayer and the laying on of hands were sincerely held religious beliefs. The burden then shifted to Texas to prove its categorical bans were the least restrictive means to achieve its compelling interests in security, solemnity, and preventing inmate suffering. The Court reasoned that Texas failed to meet this burden, as it did not show why less restrictive alternatives—such as limiting the volume of prayer, requiring silence at critical moments, or permitting touch on a part of the body away from IV lines (like a foot)—were not feasible. The Court noted that Texas's own history and the practices of other jurisdictions demonstrate that such accommodations are possible, and conjecture about potential disruptions is insufficient to justify a total ban under RLUIPA's case-by-case analysis.
Concurring - Justice Sotomayor
Yes. Justice Sotomayor joined the majority in full but wrote separately to emphasize the relationship between prison officials' duty to establish clear execution rules and the exhaustion requirement of the Prison Litigation Reform Act (PLRA). She argued that for a prison's administrative grievance process to be considered 'available' under the PLRA, it must be capable of resolving execution-related claims in a timely manner. If prison officials do not provide timely notice of rules or cause delays in the grievance process, the process may be deemed unavailable, excusing the prisoner from the exhaustion requirement.
Concurring - Justice Kavanaugh
Yes. Justice Kavanaugh joined the majority in full and wrote separately to discuss the history of this type of litigation, the difficulty of applying RLUIPA's compelling interest and least restrictive means standards, and to advise states on how to proceed. He noted that applying these standards is a difficult balancing test informed by history and contemporary practice. He advised that to avoid future litigation and delays, states should try to accommodate timely and reasonable religious requests if they can do so without meaningfully sacrificing their compelling interests in safety, security, and solemnity.
Dissenting - Justice Thomas
No. Justice Thomas argued that Ramirez's claims either do not warrant equitable relief or are procedurally barred. He contended that Ramirez engaged in a pattern of abusive and dilatory litigation, highlighted by his shifting position on the need for physical touch, which indicates his true goal is delay, not sincere religious exercise. Therefore, the equities weigh against granting an injunction. Furthermore, he argued the audible prayer claim was not properly exhausted under the Prison Litigation Reform Act (PLRA) because Ramirez failed to raise it with the required specificity in his prison grievances. The dissent emphasized the strong interest of the State and the victim's family in the timely enforcement of a lawful sentence.
Analysis:
This decision significantly strengthens RLUIPA's protections for death row inmates by applying a rigorous strict scrutiny analysis to execution chamber protocols. The ruling establishes that states cannot rely on broad, generalized concerns for security or solemnity to justify categorical bans on common religious practices. It places a heavy burden on the government to prove, on a case-specific basis, that its restrictions are the least restrictive means possible, thereby rejecting speculative fears about what might happen. This precedent will likely force states to revise their execution protocols to be more accommodating of religious requests and to develop clear, advanced procedures for handling such claims to avoid last-minute litigation and stays of execution.
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