Washington v. Klem

Henry Unseld Washington (plaintiff) was an inmate in a prison in the Pennsylvania Department of Corrections (DOC) (defendant). He founded the Children of the Sun Church and was observant for over 20 years. The church focused on promoting Pan-Afrikanism and required practitioners of the faith to read four Afrocentric books per day. The DOC had a policy that limited the amount of property inmates could keep in their cells, citing security, hygiene, and safety concerns. Specifically, inmates were allowed to keep a total of four storage boxes of personal property, but only 10 books. When Washington was informed that the number of books in his possession violated said policy, he was given the option to either mail the books, have them destroyed, or donate them to the prison library so that he could access them there. A DOC policy also limited the number of trips a prisoner could take to the library to one per week. Washington filed suit under 42 U.S.C. § 1983 and the Religious Land Use and Institutionalized Persons Act (RLUIPA), alleging that the DOC’s 10-book policy violated his First Amendment right to exercise his religion. The DOC argued that its policy did not impose a substantial burden on Washington’s ability to exercise his religion. The district court dismissed Washington’s RLUIPA claim. Washington appealed.