United States v. Chasney

On January 6th, 2021, Pro-Trump rioters led an assult on the Capitol attempting to overturn the results of the 2020 Presidential election. One of the prominent figures of the riot, Jacob Anthoney Chansley, was charged and arrested for storming the Capitol violently and his disorderly conduct inside. In late January, he was held in a correctional facility in Washington DC where he requested a religious dietary accommodation of an organic food diet because he is a Shamanic practitioner. Shamanism is a religious practice which involves a mediator who acts as a bridge between the spirit world and man. Chansley argued “because of my being a Shamanic practitioner, I only eat traditional food that has been made by God. This means no GMO’s, herbicides, pesticides, or artificial preservatives or artificial colors.” However, the detention facility claimed they were meeting his dietary needs and the counsel also debated whether his beliefs were a tenet of Shamanism. After not eating for days, Chansley’s attorney, Watkins, filed an emergency motion in the DC federal district court requesting for the jail to meet his dietary needs or that he be released. 

After Watkins filed an emergency motion, in United States v. Chansley, the court ordered dietary accommodations arguing that the First Amendment protects prisoner’s rights to challenge parts of their confinement if it amounts to a substantial burden. The court argued that the refusal to meet the dietary accommodations is a violation of Chansley’s first amendment rights for three reasons. In deciding this case, the court looked at the neutral laws post-Smith merit and found that the DOC’s decision was based on “individualized governmental assessment” of his religious practice rather than the neutral and generally applicable drug laws in Employment Division v. Smith. They also ruled that the DOCs policy is not neutral because it provides dietary accommodations for other religions, such as Muslim and Jewish inmates. In this case, the rationale was based on that Chansley’s views lacked religious merit and his requests were denied because he was a member of a disfavored sect. Lastly the Court decided that the denial of dietary accommodations is an infringement on the First because it constitutes a substantial burden to Chansley’s religious beliefs. The limitation amounted to a substantial burden because the inmate was unable to eat for over a week and claimed to have lost at least 20 pounds. After the Court’s ruling, the DC jail was unable to provide these accommodations and Chansley was transferred to another facility. 

The First Amendment states that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise of.” While it was created to build a wall between church and state, it was also established to protect the minority from the democratic tyranny of the majority. In this case, Chasney was initially denied religious accommodations for being an individual of a minority religion that the detention center did not believe was legitimate. However, I agree with the ruling made in United States v. Chasney granting Chasney an organic diet because if the government only made accommodations for more popular religions such as Judaism and Muslim, they would have been favoring those over minority religions. Therefore, even though he committed an attack on the Capitol, it is unconstitutional to not provide him dietary accommodations because he is a member of a disfavored sect. Furthermore, providing Chasney organic food does not present a “clear and present danger” West Virginia State Board of Education v. Barnette 1943 and the government’s interest is not substantial enough to burden Chasney’s First Amendment rights.

While this case exemplifies the importance of the First in protecting minority rights, it also raises the question of what constitutes as a legitimate religion and how a wall between church and state can coincide with the government ruling the religious merit of an individual. Although the First establishes a separation, the government is nevertheless involved in deciding if Chansley’s views lack religious merit or not. In granting him accommodations, other prison inmates may also make similar or other requests and the Court’s may then have to make a ruling on a case by case basis deciding what religions or religious decisions are of merit. Therefore, it is unclear how dividing the ‘wall’ actually is and this ruling may only further the entanglement of state and religion. However, Chansley’s dedication to his religion is legitimized by him starving for over a week and losing 20 pounds since he refused eating any non-organic foods. While the Court made the ruling on this case solely to its relation to the First, the decision has been criticized for law enforcement’s preferential treatment towards whites compared to minorities. Although I agree that the refusal to provide Chansley with an organic diet amounts to a substantial burden and is therefore a violation of his First Amendment rights, it will be interesting in looking at how this case may be applied in the future to other accommodations for prison inmates.