Kane v. Haynes, et al. – Do It For The Caselaw

Holding: The Ninth Circuit reversed the district court's grant of summary judgment and remanded the case for application of the Turner balancing test regarding the prisoner's free exercise claim.
Standard: Turner balancing test
Vote: The panel unanimously concluded the case was suitable for decision without oral argument.
Practical effect: Correctional facilities must now justify restrictions on religious materials by demonstrating a legitimate penological interest under the Turner factors rather than relying on summary judgment.

The Ninth Circuit reversed and remanded a district court's grant of summary judgment in a prisoner's civil rights case involving the destruction of a Quran. The appellate court held that the lower court failed to apply the required legal test for prison regulations affecting religious exercise.

Background

Ali Kane, a prisoner at the Airway Heights Correctional Center, sued correctional officers after they disposed of his unmarked Arabic-language Quran while he was being transferred. The officers offered a replacement English copy, which Kane refused because his religious practice requires prayers to be recited in Arabic. Kane filed a lawsuit under Section nineteen eighty-three of Title forty-two of the United States Code, claiming the destruction violated his First Amendment right to free exercise. The district court granted summary judgment for the defendants.

The court’s reasoning

The Ninth Circuit reviewed the case de novo. The court noted that while no party disputed Kane’s sincere belief that he needed an Arabic Quran, the district court failed to apply the multi-factor balancing test from Turner versus Safley. The appellate court held that the district court did not evaluate whether the government demonstrated a legitimate penological interest justifying the regulation. Consequently, the court reversed the summary judgment and remanded the case for the district court to consider the Turner factors.

What it means going forward

Correctional facilities must now justify restrictions on religious materials by demonstrating a legitimate penological interest under the Turner factors rather than relying on summary judgment.