## Facts

- Wesley Spratt, a maximum-security inmate serving a life sentence, underwent a religious conversion and regularly attended Christian services at the Rhode Island Adult Correctional Institution.
- Prison chaplains permitted Spratt for years to preach during weekly services, meaning he would comment on and expound religious texts to other inmates.
- Spratt was ordained as a minister in 2000.
- From 1995 to 2003, prison officials allowed Spratt to preach and the record reflected no resulting disciplinary or security problems.
- After a new warden took office in 2003, Spratt was told he could no longer preach and was warned he would face discipline if he did so.
- The warden cited a department policy providing that religious services are scheduled, supervised, and directed by institutional chaplains.
- The department permitted Spratt to read scripture aloud without commentary but prohibited him from preaching or otherwise leading religious services.
- The corrections director rejected Spratt’s complaint, stating that religious exercise was subject to reasonable restrictions and that chaplain-directed services were reasonable.

## Issues

1. Whether the prohibition on inmate preaching imposed a substantial burden on Spratt’s religious exercise under RLUIPA.
2. If so, whether the department proved that the prohibition furthered a compelling governmental interest and was the least restrictive means of doing so.

## Decision

- The First Circuit held that the prohibition substantially burdened Spratt’s religious exercise under RLUIPA.
- The court accepted prison security and order as potentially compelling interests but held that the department did not, on summary judgment, carry its burden to show the blanket ban was the least restrictive means.
- The court reversed the grant of summary judgment for the department and remanded for further proceedings.

## Legal Principles

- RLUIPA bars the government from imposing a substantial burden on an institutionalized person’s religious exercise unless the government proves the burden is the least restrictive means of furthering a compelling governmental interest.
- “Religious exercise” is construed broadly and can include practices not compelled by, or central to, a faith tradition; sincerity is the relevant inquiry.
- A policy substantially burdens religious exercise when it prevents an inmate from engaging in conduct the inmate sincerely believes is religiously required or part of a religious calling.
- Once a substantial burden is shown, the government must support asserted security concerns with evidence grounded in fact; conclusory or speculative justifications are insufficient.
- Under the least-restrictive-means requirement, the government must explain why less restrictive alternatives (e.g., supervision, limits, or individualized assessments) would not adequately address the asserted interest.

## Conclusion

The court held that barring Spratt from preaching imposed a substantial burden under RLUIPA and that the department’s generalized security rationale, without evidentiary support or consideration of less restrictive alternatives, could not justify summary judgment for a categorical prohibition on inmate preaching.


Spratt v. R.I. Dep’t of Corr., 482 F.3d 33 (1st Cir. 2007)