Ramirez v. Collier

Religious Land Use and Institutionalized Persons Act of 2000 states that the state cannot impose substantial burden on the exercise of religion to people in state institutions unless the government proves the burden “(1) is in furtherance of a compelling governmental interest; and (2) is the least restrictive means of furthering that compelling governmental interest.” 2 U. S. C. §2000cc–1(a).

Petitioner appealed a decision by the Texas Department of Criminal Justice that denied him the opportunity to have his spiritual advisor lay hands upon him and pray aloud during his execution. Petitioner argued that he is entitled to a primary injunction against his execution and cited cited the RLUIPA as the basis for his claim which states that the state cannot impose substantial burden on the exercise of religion to people in state institutions unless the government proves the burden “(1) is in furtherance of a compelling governmental interest; and (2) is the least restrictive means of furthering that compelling governmental interest.” 2 U. S. C. §2000cc–1(a). Respondent argued that Petitioner failed to prove an exhaustion of remedies as required under the Prison Litigation Reform Act of 1995 (PLRA). In addition, Respondent argued that silence is needed in the execution chamber to monitor the inmate’s condition and that touching the inmate could interfere with the IV line in the arm. The Court held that Petitioner was likely to succeed on the merits of the claim given the justifications that Respondent offered, and also found that the limited remedy in this case was appropriate for the further resolution of the legality of Texas’s execution policies. The judgment of the United States Court of Appeals for the Fifth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.