Clifton Williams has been a practicing Muslim for 20 years but is currently incarcerated at State Correctional Institution Mahanoy. During one of his scheduled work times in the kitchen he had not yet been given any assignments, so he decided to complete one of his five daily prayers. He found an isolated corner away from the working area where he could pray, but prisoners were not permitted to occupy unauthorized areas on their own. After five minutes of prayer he was ordered to return to his duties in the kitchen but he refused; he was eventually removed from the kitchen and taken back to his cell. Williams was punished for refusing to obey an order, and for occupying an unauthorized area. Williams pleaded guilty to the misconduct charges because, in the Muslim faith, once a prayer has commenced one must continue until it is finished. Williams filed a civil rights action pursuant against SCI Mahanoy for violating the Free Exercise Clause of the First Amendment. In order for there to be a violation, he must show that the facility prevented him from “engaging in his religion without any justification reasonably related to legitimate penological interests.”
Balancing the rights of the incarcerated and maintaining a safe environment for the inmates as well as the guards is a complex topic. Based on the ruling, it was determined that there was no violation of the Constitution because the guards have an obligation to maintain safety and security within the prison. With nearly 400 inmates and just 26 guards, the inmates cannot be left alone in an unauthorized area. Prisoners also have plenty of time to pray in their cell, that is why they are not permitted to pray during work hours. The conflict here is whether or not the prison should make accommodations for Muslim inmates so that they can have access to a clean room for prayer. In the past, during Ramadan, the facility provided a separate room for Muslim inmates to pray. In the meantime, prisoners are supposed to use the break room and or their cells to practice Salah. Williams complained that the break room did not suffice because other inmates tracked dirt and urine on the floor. I feel that making a special room for prayer would be an accommodation that violates the Lemon Test, because it would favor Islam and it would not serve a secular purpose. Another solution would be to implement a new ‘leave and return’ policy which would allow inmates to leave work in order to go and pray. This would require the inmates, like Williams, to be removed from work with an escort. However, this could cause further conflict by weakening the security force overlooking the inmates in the kitchen, and other prisoners would take advantage of this accommodation to get out of work. I feel that in order to maintain a maximum security level, without making special religious accommodations, and enabling the Muslim inmates to practice their religion with relative freedom; their five prayers must take place in their designated cells or in the break room. This would not interfere with their labor hours, nor would it jeopardize the level of security within the prison.
4 comments:
I mean...at the end of the day, he's in jail. When you are in jail, certain rights are taken away, like perhaps the right to properly worship how your wish. I think that the jail was justified in removing him and returning him back to his cell, especially because they tried to get his attention and he refused. Christians are not allowed to attend their required Sunday service at their desired local church, because they are in jail. this is not an issue of free exercise, because the individual is in jail.
I agree with Tntbo that the policy regarding this prayer should not be modified. The guards acted appropriately when they ordered Williams to begin work and then put him back in his cell. He should not have been praying during work with the expectation that he would not be interrupted. Also, to make special accommodations for Muslim prisoners would be inappropriate as they are able to pray in their cells or the break room. These individuals are in jail, and they have no legitimate expectation of ideal circumstances to practice their religion.
I agree with Thomas in his opinion that in order to maximize safety and security in the prison at all times the prisoner was rightfully sent back to his cell. There is plenty of time for the prisoner to say his prayers within his own jail, without interruption. I do not feel this was a violation of the free exercise clause because of the circumstances. Kitchen work in a jail community has different implications than working in a regular kitchen at a restaurant. Secondly, giving Muslim prisoners special accommodations would be favoring one religion over another. If Muslims are given special accommodations then Christians, Jews, and other religions should be given equally favorable ones as well, which cannot be expected within the confines of a jail
I disagree with the above comments. Yes this man is in jail but he still has fundamental rights. Even though the government has a compelling interest in maintaining the security of the prison, they MUST pursue this interest in the least restrictive means. The prison most definitely has the ability to make accommodations for the prison while still maintaining security.
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