Baranowski v. Hart

Thomas Baranowski (plaintiff) was incarcerated in a prison under the control of the Texas Department of Criminal Justice (TDCJ). Baranowski was a practicing member of the Jewish faith. The prison had a large chapel; however, Jewish services were held monthly in the educational department. After two of the prison’s Jewish services were canceled, Baranowski filed suit under the Free Exercise Clause, Equal Protection Clause, and Religious Land Use and Institutionalized Persons Act (RLUIPA). Baranowski alleged that TDCJ officials (defendants) deprived him and other Jewish inmates of access to the prison chapel for their religious observances, that other faiths were treated more favorably, and that weekly inmate-led services should be held. TDCJ officials moved for summary judgment and filed affidavits in support thereof. The affidavits stated that the services were canceled due to the unavailability of a rabbi to conduct the services, that the TDCJ recognized several Jewish holy days and allowed inmates to observe, that less than one percent of the Texas inmate population was Jewish, and that the chapel was used for a simultaneous religious service with a larger number of attendees. The TDCJ further argued that it had valid penological objectives, such as security and space limitations, to justify its policies. The district court granted summary judgment in favor of the TDCJ officials.