Case: Pierce v. LaVallee

This is a historic case about religious liberty and discipline in New York prisons. It's part of the Clearinghouse's collection of several cases brought by prisoners rights activist (and prisoner) Martin Sostre, whose wikipedia biography is here. 

Sostre brought this lawsuit to challenge policies surrounding religious expression at Clinton State Prison in New York. In August 1959, prison officials charged Sostre and two other individuals with “agitating.” The plaintiffs sued the Clinton State Prison warden in the U.S. District Court for the Northern District of New York under §1983 and state law. Sostre alleged that prison officials had denied him access to the Koran, subjected him to solitary confinement and deprived him good time credits because of his religious beliefs, and denied him permission to establish contact with a spiritual advisor.

While we do not have information about the early stages of the litigation, the district court held a trial on the issue of the prison denying Sostre access to the Koran. The court explained this decision: the other claims concerned matters of prison discipline that could be reviewed only in the state courts. At this point, Sostre no longer pursued the issue regarding the right to contact a spiritual advisor but continued to seek to relief regarding solitary confinement and deprive of good time credits.

The case reached the Second Circuit Court of Appeals after that trial, and the appellate court issued its opinion on July 31, 1961. 293 F.2d 233. Sostre’s appeal was consolidated with appeals in cases brought by two other men incarcerated at Clinton. The appeals court looked to cases from the Ninth and Seventh Circuits, which had held that prison discipline-related claims belonged in state courts. But the Second Circuit distinguished this case, because the plaintiffs before it had sought relief on religious liberty grounds, instead of solely physical abuse or restrictions on liberty. The doctrine of Pullman abstention did not pose a bar because there were no unresolved questions of state law, and the defendant did not give a reason why a state forum would be better. Thus, the federal district court could hear all of the plaintiffs’ remaining claims. Judge Dawson, a district court judge sitting by designation, dissented from this opinion, arguing that the plaintiffs had abandoned these issues. (This was prior to the landmark case of Cooper v. Pate, 378 U.S. 546 (1964), in which the U.S. Supreme Courr held that a similar claim about discriminatory prison denial of access to Muslim texts properly alleged a constitutional violation, citing Pierce v. LaVallee.)

The Second Circuit then remanded the case back to the district court. This remand excluded the issue about the right to purchase the Koran, because the Commissioner of Correction had issued a directive to New York prison wardens that approved four different Koran translations. These translations included the one sought by the plaintiffs.

Back in the district court, the court held a trial on the plaintiffs’ claims that they had been disciplined solely because of their religious beliefs. On May 11, 1962, the court issued its opinion. It held that the plaintiffs had each individually failed to establish that the discipline was imposed solely because of their religious beliefs, so the complaint in each individual action should be dismissed. It found that the Muslim Brotherhood was an organization instead of a religious practice and credited the defendant’s concern that the plaintiffs’ activities would cause unrest in the prison. 212 F.Supp. 865.

The plaintiffs appealed again to the Second Circuit; on July 18, 1963, the court of appeals affirmed the district court’s order. 319 F.2d 844 (per curiam). And the Supreme Court subsequently denied each of the three plaintiffs’ petitions for certiorari review. Sostre v. Wilkins, 374 U.S. 850 (June 17, 1963); Pierce v. Lavallee, 376 U.S. 918 (Feb. 17, 1964); Samarion v. McGinnis, 379 U.S. 950 (Dec. 14, 1964).

The case is closed.