Winters v. State, 95-723
| Decision Date | 19 June 1996 |
| Docket Number | No. 95-723,95-723 |
| Citation | 549 N.W.2d 819 |
| Parties | Jeffrey WINTERS, Appellant, v. STATE of Iowa, Appellee. |
| Court | Iowa Supreme Court |
Patrick Ingram of Mears Law Office, Iowa City, for appellant.
Thomas J. Miller, Attorney General, and William A. Hill, Assistant Attorney General, for appellee.
Considered by HARRIS, P.J., and LARSON, CARTER, NEUMAN, and ANDREASEN, JJ.
Prison inmate Jeffrey Winters, who is white, was found guilty of violating prison rule 23 (disobeying an order) when he refused to share a cell with a black inmate. Winters' refusal was based on his claim that racial separation is a doctrine of the Church of Jesus Christ Christian, of which he is a member. Winters received forty days disciplinary detention and a loss of sixteen days good-conduct time. He exhausted his administrative remedies and filed an application for postconviction relief.
Following a hearing, the postconviction court found that Winters failed to reasonably support, and thus failed to prove, his claim that he has a sincerely held religious belief that required he be given a racially segregated cell. The district court did not accept Winters' argument that it should apply a newly heightened scrutiny of this type of religious liberty claim by reason of the Religious Freedom Restoration Act of 1993 (RFRA), 42 U.S.C. § 2000bb.
Winters claims that the court erred when it refused to apply the RFRA in adjudicating his claims. Congress passed the RFRA in 1993. This legislation restored the compelling-interest test for reviewing governmental action challenged under the Free Exercise Clause of the First Amendment. Brown-El v. Harris, 26 F.3d 68, 69 (8th Cir.1994). The law is retroactive. Id. The RFRA provides the standard of review in controversies involving prison rules that are alleged to burden prisoners' religious practices. See Allah v. Menei, 844 F.Supp. 1056, 1061 (E.D.Pa.1994).
Under the RFRA, a governmental entity may substantially burden a person's exercise of religion only if it demonstrates that the application of that burden is (1) in furtherance of a compelling governmental interest, and (2) is the least restrictive means of furthering that compelling governmental interest. 42 U.S.C. § 2000bb-1.
Although the district court recognized the renewal of the compelling-interest standard of review and the Act's retroactive effect, it was persuaded not to apply the new standard because Winters did not specifically base his claim on the RFRA. Because the RFRA is of general application in reviewing all free-exercise challenges to governmental action, we do not share the district court's view that it must be specifically alleged as the basis for a particular claim. This conclusion, however, does not affect the outcome of the present dispute.
Notwithstanding the degree of scrutiny engendered by the RFRA, the efficacy of restrictions on the fundamental rights of inmates requires recognition of the competing interests at stake. Thornburgh v. Abbott, 490 U.S. 401, 407, 109 S.Ct. 1874, 1878, 104 L.Ed.2d 459, 469 (1989); Allah, 844 F.Supp. at 1060. On the one hand, it is firmly established that convicted prisoners do not forfeit all constitutional protections by reason of their conviction and confinement in prison. Turner v. Safley, 482 U.S. 78, 84, 107 S.Ct. 2254, 2259, 96 L.Ed.2d 64, 70 (1967); Allah, 844 F.Supp. at 1060. The Supreme Court has required that "prisoners be accorded those rights not fundamentally inconsistent with imprisonment itself or incompatible with the objectives of incarceration." Monmouth County Correctional Inst. Inmates v. Lanzaro, 834 F.2d 326, 333 (3d Cir.1987) (citing Hudson v. Palmer, 468 U.S. 517, 523, 104 S.Ct. 3194, 3198, 82 L.Ed.2d 393, 401 (1984)).
On the other hand, lawful incarceration brings about the necessary withdrawal or limitation of many significant privileges. Thornburgh, 490 U.S. at 408, 109 S.Ct. at 1879, 104 L.Ed.2d at 469-70; Allah, 844 F.Supp. at 1060. Some burden on the exercise of constitutional rights otherwise enjoyed arises from the fact of incarceration and from valid penological objectives--including deterrence of crime, rehabilitation of prisoners, and institutional security. Id. Running a prison is an inordinately difficult undertaking that requires...
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