Is There an Interesting Recent U.S. Supreme Court Case?
May 1, 2022 | View PDF
There is a case decided in March 2022 arising out of the state of Texas. Factually, it involved the horrific murder of Texas resident Pablo Castro in 2004 by John Ramirez [and two other assailants] for less than $2.00. [All three were convicted of three robberies that same night]. One woman managed to escape unharmed by giving the three her purse after the knife used to kill Castro was held to her neck in front of her 2-year-old son. Another woman escaped in her vehicle after the trio attempted to rob her in a fast food drive through line.
The vehicle with the perpetrators in it was identified and pursued by police until it ended in a foot chase. Two accomplices were captured, the killer managed to escape and went to Mexico where he was later arrested near the border just over three years later. Ramirez was sentenced to death in 2008. For over a decade, Ramirez managed to prolong the visit to the death chamber by lethal injection.
Ramirez filed a prison grievance that he wanted his spiritual advisor in the execution chamber during his execution. Initially Texas refused it then later determined that it would be allowed. Ramirez then filed a Step 1 Grievance in June 2021, not only to allow his spiritual advisor in the death chamber but also to be given the ability to verbally utter prayers and to “lay hands on him,” which Ramirez stated was a part of his religion. His pastor stated affirmatively. Texas refused, saying it was not a part of its protocols when in fact it had been allowed. Ramirez then appealed with a Step 2 Grievance and, because Texas did not act with only a month until the execution, he filed suit through the Federal District Court. The suit asserted under the Religious Land Use and Institutionalized Persons Act of 2000 and the First Amendment. Ramirez sought preliminary and permanent injunctive relief unless such religious accomodation was allowed in the death chamber. The Complaint was amended to include the pastor audibly praying and laying hands on during the execution. Texas refused and was supported by the Federal District Court as well as the Fifth Circuit as well as a stay of the execution. A Writ of Certiorari was filed with the United States Supreme Court and the Court agreed to hear the case.
The issue is whether the execution should be halted for full consideration. However, to do so Ramirez, “must establish that he is likely to succeed on the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest.” Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7, 20. I must say I got a bit of a chuckle out of the test consisting of “irreparable harm” when Ramirez was definitely facing that but not because of the issue at hand. Under 42 U. S. C. §2000cc–1(a). A plaintiff bears the initial burden of proving that a prison policy “implicates his religious exercise.” Holt v. Hobbs, 574 U. S. 352, 360. A prisoner’s requested religious accommodation “must be sincerely based on a religious belief and not some other motivation.” Id., at 360–361. The burden on the prisoner’s religious exercise must also be “substantial.” Id., at 361.Pp. 9–18. Looking at Texas execution protocol and history it does not appear that the allowance as requested by Ramirez will restrict the state from carrying out its compelling governmental interests and it does not appear that the burden on Texas would be substantial. Texas was also concerned that the allowance of a verbal prayer could allow for the exploitation of a “statement” to be made but the Supreme Court did not see that considering the sincerity of Ramirez’s pastor. It was also felt that the Religious Land Use and Institutionalized Persons Act of 2000 [RLUIPA] would succeed on its merits. The lower Court opinions were reversed and remanded back to the trial Court for reconsideration on the merits. Chief Justice Roberts wrote the majority opinion as well as concurring opinions written by Justices Kavanaugh and Sotomayor.
Surprisingly only Justice Thomas voted in dissension and wrote a dissenting opinion. His feeling was that Ramirez, through numerous and various procedures, had long delayed his execution. Thomas wrote, “In RLUIPA, Congress created a potent tool with which prisoners can protect their sincerely held religious beliefs. But, like any tool, it can be wielded abusively. And few have a greater incentive to do so than death-row inmates. To counter such abuse, federal courts sitting in equity have a duty to dismiss piecemeal, late-breaking, dilatory, specious, speculative, or manipulative litigation. RLUIPA itself complements that process by requiring a prisoner to demonstrate sincerity.
Meanwhile, Congress passed the PLRA [The Prison Litigation Reform Act 42 U.S.C. § 1997e] to force prisoners to exhaust their complaints through state prisons’ administrative review processes so that prison officials might resolve, or at least build a record to help shed light on, an alleged problem before it escalates to litigation. Federal courts have a duty under the PLRA to dismiss these unexhausted claims.
Today, the Court shrugs off both of these duties. It grants equitable relief for a demonstrably abusive and insincere claim filed by a prisoner with an established history of seeking unjustified delay, harming the State and Ramirez’s victims in the process. The Court also forgives the same prisoner’s complete failure to exhaust another claim. Because I would deny equitable relief for the first claim and dismiss the second under the PLRA, I respectfully dissent.”
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