Calif. inmate’s prayer-oil case moves forward
A California inmate successfully survived a motion to dismiss his case in federal court, as a judge allowed his religious-liberty complaint to move forward over the denial of prayer oils.
David Rentz II, an inmate at Calipatria State Prison, sued in July 2011 after prison officials confiscated his prayer oils in August 2010. Rentz claimed the oils were necessary to practice his religious beliefs. Several religions use oils in prayer; the opinion did not specify Rentz’s faith.
In February 2010, a prison-official committee had decided that prayer oils could be banned because they were potentially flammable and presented a safety risk.
Normally, such evidence would be a death knell to an inmate’s constitutional claim under the deferential standard used in prisoner cases from Turner v. Safley (1987). Under this Supreme Court decision, a prison policy is upheld as long as prison officials have a legitimate penological reason — safety or rehabilitation — for their actions.
However, Rentz, representing himself, produced some interesting evidence. He included in his complaint a July 2010 letter from an associate warden to another inmate. In letter, the associate warden writes that “the purchase and distribution of prayer oil was temporarily suspended by Warden Larry Small due to an issue of flammability.” But then the letter goes on to say that prison officials later determined “there is no compelling reason to deny the oils from the vendors that have been approved by the Institution in the past.”
Prison officials in Rentz’s case also attached the letter to their legal papers. The court wrote that “both parties have submitted a document that would suggest that prison officials reversed their finding and lifted their prayer oil ban prior to the confiscation of Plaintiff’s prayer oils.”
On the basis of this evidence, U.S. District Judge Irma E. Gonzalez for the Southern District of California refused to dismiss Rentz’s complaint in her Dec. 11 decision in Rentz v. Borem. In light of the letter from the associate warden, Gonzalez found “the ban on prayer oil due to flammability does not support a finding of a legitimate penological reason for Defendant allegedly confiscating Plaintiff’s prayer oil on August 20, 2010.”
Gonzalez noted that the associate warden’s letter was written in July 2010 and the confiscation of Rentz’s prayer oils was a month later.
Prison officials also tried to argue that allowing prayer oils imposed unnecessary costs on the prison. The judge rejected that contention, noting that prayer oils were previously allowed and there was “no basis for the argument.”