CHICAGO (CN) – An Illinois inmate will get second chance to prove that prison officials infringed on his religious rights by cutting bimonthly services of his faith for budgetary reasons.
Mannie Maddox, an African Hebrew Israelite (AHI) since 1998, was incarcerated at the Lawrence Correctional Center from March 2004 to August 2007.
While serving time, Maddox regularly attended AHI services until the prison canceled them in September 2004. Maddox continued to practice his faith by reading religious literature but filed a grievance, which was denied.
Prison Chaplain Timothy Love refused Maddox’s request to allow AHI inmates to meet as a group under supervision. To reduce gang-related activity, groups of inmates are not allowed to meet regularly without the supervision of the chaplain.
Love, who conducts supervised services and religious study period for Christians, Catholics, Muslims, Moorish Science Temple followers, Jehovah’s Witnesses and Jews, as well as nondenominational events, said his schedule would not allow for an additional meeting.
Maddox then filed suit in federal court, alleging violations of his constitutional right to free exercise of his religion and equal protection under the law.
Maddox claimed that the prison had failed to provide reasonable access to religious materials to AHI followers, discriminated in the allocations of the prison’s religions budget, and failed to provide group worship services allowed to other religions.
U.S. District Judge J. Phil Gilbert dismissed the reasonable access claim, finding that his complaint alleged deprivation of religious services, not religious materials. He then granted summary judgment to the prison, asserting that Maddox did not properly exhaust administrative remedies because he did not name the prison officials allegedly responsible for the violation in his grievance.
But the 7th Circuit disagreed, vacating the ruling and remanding for further proceedings.
Maddox made a reasonable constitutional claim by arguing that the prison had allocated “a disproportionately small share of the Lawrence religious budget … to [AHI] activities,” and Gilbert should not have rejected it, the court ruled.
Additionally, Maddox’s claims could not be blocked on administrative-procedure grounds because inmates were not formally required to list specific individuals responsible at the time that Maddox filed the grievance.
“Where prison officials address an inmate’s grievance on the merits without rejecting it on procedural grounds, the grievance has served its function of alerting the state and inviting corrective action, and defendants cannot rely on the failure to exhaust defense,” Judge John Tinder wrote for the three-judge panel.
In May 2009, the Lawrence Correctional Center reported inmates of 46 different religious, including 647 Christians, 313 Baptists, 299 Catholics, 119 Muslims, 32 Moorish Science Temple followers, 30 Jehovah’s Witnesses, 28 AHIs and five Jews.