O'lone v. Estate Of Shabazz (1986)
- Docket
- 85-1722
- Decided
- 1986-01-01
Summary
Question: If a prison policy infringes on inmates’ free exercise of religion, must the prison show that there are no reasonable alternatives that would accomplish the same goal without creating an actual security issue? Conclusion: No. Chief Justice William H. Rehnquist delivered the opinion for the 5-4 majority. The Court held that, while prisoners do not forfeit their constitutional rights after being convicted of a crime, being incarcerated does place necessary limitations on those rights. Because of the particular interests and dangers involved in prisons and the prison administration’s everyday experience with the operation of a prison, courts should largely defer to prison administrators on questions of policy or regulation. Therefore, even when an inmate alleges that a prison policy infringes on his or her constitutional rights, the policy is valid as long as it is reasonably related to a legitimate penological objective, as the policy in this case was. The Court also held that a prison is not required to adopt any alternative policy that may have “undesirable results,” as determined by the prison. Justice William J. Brennan, Jr. wrote a dissent in which he argued that a prison must demonstrate that the restrictions imposed on inmates were necessary to further an important governmental interest. He also argued that there should be a varying level of scrutiny depending on the nature of the right being asserted, rather than the general standard of deference in the majority opinion. Because the prison policy in the case in question acts as a complete ban that prevents some Muslim prisoners from attending Juamu’ah, an obligatory and important religious ceremony, the prison should be required to show the policy was necessary and no less extreme measures could serve the same purpose. Justice Thurgood Marshall, Justice Harry A. Blackmun, and Justice John Paul Stevens joined in the dissent,