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Court refused to hear inmates claims related to violation of freedom of religion. Word v. Croce, 00 Civ. 6496 (SAS) (S.D.N.Y. Jul. 6, 2001)


Inmates in New York have rights to practice their religion, protected under the First Amendment of the United States Constitution. These rights include the freedom to believe in and worship any religion of their choice. The New York Department of Corrections is required to accommodate inmates’ religious practices to the extent that it doesn’t interfere with prison security or discipline. This means providing reasonable opportunities for religious services, access to religious materials, and dietary accommodations for religious beliefs.

However, these rights are not absolute. Prison officials can impose restrictions on religious practices if they have a legitimate penological interest, such as maintaining order or security within the facility. Inmates may also face limitations if their religious practices pose a threat to themselves or others, or if accommodating their practices would place an undue burden on the prison system.

Inmates who believe their religious rights have been violated can seek recourse through the legal system. They may file grievances within the prison system or pursue legal action in state or federal court. Courts will consider the inmate’s claims and weigh them against the prison’s interests in maintaining security and order.

In this case, the plaintiff, acting pro se, sought relief from a judgment issued by the Court on April 27, 2001, dismissing her complaint related to denial of her rights related to freedom of religion.

Background Facts
The plaintiff, who was incarcerated at Bedford Hills Correctional Facility in New York, filed a motion challenging a previous court ruling dated April 27, 2001. In that ruling, the court had dismissed a complaint filed by the plaintiff. Seeking relief, the plaintiff invoked Rule 60(b)(1)-(5) of the Federal Rules of Civil Procedure. The plaintiff contended that the prison authorities had disregarded their religious beliefs and medical requirements. Notably, these arguments were not initially raised in the plaintiff’s original complaint. Allegations included claims of inadequate consideration of religious beliefs and insufficient medical care, particularly concerning medical tests, dietary preferences, and access to specific healthcare professionals. the The lower court concluded that the arguments presented in the motion did not justify granting the requested relief. The plaintiff appealed.

The key issue revolves around whether the plaintiff’s new arguments justify reconsideration of the previous judgment, particularly regarding religious exemptions from medical procedures and dietary requests.

The court denies the plaintiff’s motion for relief, finding her arguments insufficient to warrant reconsideration or amendment of the judgment. The court emphasizes that plaintiff’s religious claims were not part of the original complaint and cannot be introduced through motion practice.

The plaintiff’s motion hinges on several arguments, including claims of deliberate indifference by the defendants and assertions of religious exemptions from medical procedures and dietary requirements. However, the court finds these arguments lacking in merit. The plaintiff’s reliance on the Reynolds v. Goord103 F. Supp.2d 316 (S.D.N.Y. 2000) case, which dealt with religious exemptions from medical procedures, is deemed inappropriate as her original complaint did not raise religious grounds. Consequently, the court cannot entertain new claims introduced through motion practice. Moreover, the plaintiff’s vague reference to “newly discovered evidence” fails to meet the stringent criteria required for such claims. Additionally, the court dismisses other arguments presented by the plaintiff as attempts to re-litigate issues already decided. Overall, the court concludes that the plaintiff’s motion does not provide sufficient grounds to warrant reconsideration or amendment of the previous judgment.

In light of the foregoing analysis, the court denies the plaintiff’s motion for relief. The plaintiff’s arguments fail to meet the necessary criteria for reconsideration or amendment of the judgment. The court emphasizes that new claims cannot be introduced through motion practice and that attempts to re-litigate issues already decided are not permissible. Therefore, the plaintiff’s motion is dismissed, and the Clerk of the Court is directed to close the case.

If you or someone you care about is an inmate at Bedford Hills or any other correctional facility in New York and you believe your rights have been abused, contact an experienced New York prison rights lawyer at Stephen Bilkis & Associates.

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