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Spratt v. Rhode Island Department of Corrections

482 F.3d 33 (2007)

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Spratt v. Rhode Island Department of Corrections

United States Court of Appeals for the First Circuit
482 F.3d 33 (2007)

Facts

Wesley Spratt (plaintiff) was serving a life sentence for murder. During his incarceration, he underwent a religious awakening and became a devout Christian. Spratt began preaching to inmates at the weekly prison services. After eight years of preaching, a new prison warden informed Spratt that he was not allowed to preach to inmates because it violated the Rhode Island Department of Corrections’ (RIDOC) (defendant) policy that religious services be directed by institutional chaplains. Spratt filed suit under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and alleged that the policy violated his First and Fourteenth Amendment rights. An RIDOC official filed an affidavit, claiming that the policy was the least-restrictive means of promoting the compelling governmental interest in safety because placing an inmate in a position of perceived leadership gives that inmate influence over the prison population. The district court granted summary judgment in favor of the RIDOC. Spratt appealed.

Rule of Law

Issue

Holding and Reasoning (Torruella, J.)

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