Thursday, November 7, 2013

Cutter v. Wilkinson case brief

Cutter v. Wilkinson case brief summary
544 U.S. 709 (2005)

Petitioners, current and former inmates of Ohio state institutions, sought certiorari review of a judgment from the United States Court of Appeals for the Sixth Circuit, which reversed a district court ruling on interlocutory appeal and held that § 3 of the Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C.S. § 2000cc-1(a)(1)-(2), improperly advanced religion in violation of U.S. Constitutional Amendment I's Establishment Clause.

The inmates alleged that respondent prison officials violated 42 U.S.C.S. § 2000cc-1 by failing to accommodate their exercise of nonmainstream religions in several ways. The circuit court held that the district court erred in rejecting the officials' facial challenge to § 2000cc-1 and in denying their motion to dismiss the inmates' claim.

The Court reversed the circuit court's judgment. The Court held that § 2000cc-1, on its face, qualified as a permissible accommodation that was not barred by the Establishment Clause. Section 2000cc-1 was compatible with the Establishment Clause because it alleviated exceptional government-created burdens on private religious exercise. Further, § 2000cc-1 did not elevate accommodation of religious observances over an institution's need to maintain order and safety. Finally, the Court found that § 2000cc-1 did not differentiate among bona fide faiths because it conferred no privileged status on any particular religious sect. The circuit court misread the Court's precedents to require invalidation of § 2000cc-1 as impermissibly advancing religion by giving greater protection to religious rights than to other constitutionally protected rights.


The Court reversed the judgment. The Court remanded the case for further proceedings.

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