Appeals Court Overturns Ban on Christian Preacher in Rhode Island Prison

April 9, 2007 12:00 am

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ACLU Calls Ruling a Victory for Religious Freedom

BOSTON – In an important victory for religious freedom, a federal appeals court ruled that Rhode Island corrections officials cannot bar a Christian prisoner from preaching during religious services at the state prison. The ruling comes in a case brought by the American Civil Liberties Union of Rhode Island.

“Religious freedom is too precious a right to be arbitrarily denied to individuals in the custody, and at the mercy, of government officials,” said Steven Brown, Executive Director of the ACLU of Rhode Island.

The U.S. Court of Appeals for the First Circuit overturned a district court decision that allowed the Adult Correctional Institute (ACI) to bar Wesley Spratt from preaching during weekly religious services. Spratt, who is a lay minister, had preached at the ACI without incident for seven years before he was unilaterally stopped from doing so by a new warden in 2003. The warden cited vague security concerns in his decision. Spratt challenged the ban, but a district court judge sided with the warden.

In Spratt’s appeal, ACLU of Rhode Island cooperating attorney Lynette Labinger argued that the preaching ban violated a federal law designed to protect the religious freedom of institutionalized persons. That law, known by its acronym RLUIPA, bars states from imposing any substantial burden on a prisoner’s exercise of religion unless it furthers a compelling interest and is the least restrictive means available. The appeals court agreed with the ACLU that the state had failed to demonstrate that the ban was the least restrictive means necessary to promote the prison’s interest in security, and ordered a trial on the merits of the case.

“This court ruling makes clear that mere generalizations and rank speculation cannot provide the basis for stifling the religious freedom of prisoners,” said Brown.

Spratt, who says he experienced a spiritual awakening in prison and considers his preaching a “calling” from God, had been preaching at religious services under the supervision, and with the support, of clergy at the ACI. Corrections officials provided no evidence of security problems during, or as the result of, his supervised preaching.

“Spratt’s seven-year track record as a preacher, which is apparently unblemished by any hint of unsavory activity, at the very least casts doubt on the strength of the link between his activities and institutional security,” said the appeals court in its ruling. “While we recognize that prison officials are to be accorded substantial deference in the way they run their prisons, this does not mean that we will rubber stamp or mechanically accept the judgments of prison administrators.”

The decision was made public late Friday. It is available online at:

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