VICTORY: American Humanist Association and Kwame Jamal Teague, v. Frank L. Perry, et al.
The Appignani Humanist Legal Center (AHLC) challenged North Carolina’s prison system’s discrimination against Humanist inmates in a case filed on behalf of state prisoner, Kwame Jamal Teague, and other AHA members within North Carolina’s prisons. The AHLC filed its lawsuit on February 26, 2015, in the U.S. District Court for the Eastern District of North Carolina, arguing that the state is discriminating against Humanist inmates in violation of the First and Fourteenth Amendments.
On March 17, 2017 the court (Judge James C. Fox) granted our discovery motion, requiring the state to produce numerous records pertaining to its disparate treatment of Humanists with respect to group meetings and other privileges. In the order, the court recognized that Supreme Court precedent requires Humanism to be treated as a “religion” for First Amendment purposes. Shortly thereafter, Judge Fox resigned and the case was reassigned to Judge Terrence W. Boyle.
On July 28, 2017 the parties filed cross-motions for summary judgment. A summary judgment hearing was held on January 24, 2018 in Raleigh, where AHA’s Senior Counsel Monica Miller argued that the State’s discrimination against Humanist inmates failed to meet constitutional standards. Miller assured Boyle that there was sufficient demand for Humanist services, noting that the state regularly allows religious group meetings with only two to three inmates present. Accompanying Miller at the hearing was AHA’s paralegal Isabelle and plaintiff Kwame Teague.
On March 29, 2018 the court granted our motion for summary judgment motion. Judge Boyle found that the North Carolina violated both the Establishment Clause of the First Amendment, as well as the Equal Protection Clause of the Fourteenth Amendment, and issued the following order:
The court enters a permanent injunction ordering Defendants, their agents, successors, and any person in active concert with the Defendants: (a) to recognize Humanism as a faith group and as an assignment option for OPUS and all other prison records; and (b) permit Teague and other Humanist inmates to meet in a Humanist study group on the same terms defendants authorize for inmates of recognized faith groups…The court enters a declaratory judgment stating that defendants' have violated the Establishment and Equal Protection Clauses by refusing to recognize Humanism as a faith group and by refusing to offer Humanism as an assignment option for OPUS and other prison records.
In the 19-page opinion, Judge Boyle explained in part:
Defendants, additionally, have not set forth any evidence to support space, resource, or security concerns applicable to Humanist inmates, which do not apply equally to Christian, Muslim, Buddhist, or Wiccan inmates.
. . . Rather, on the record before the court, DPS's arbitrary decision to recognize some faith groups, and not Humanism, fostered an excessive government entanglement with religion. . . .
Additionally . . . plaintiffs have provided evidence of discriminatory intent through DPS's bias against Humanism and the fact that prison officials required him to submit materials beyond what is typically required in support of his request for recognition of Humanism as a faith group. . . .
. . . [T]here is no rational connection between DPS's cited interests and its refusal to recognize Humanism as a faith group. As stated, it does not appear from the summary judgment record that size or demand played a role in DPS's refusal to recognize Humanism. Indeed, other faith groups have been recognized with as few as two interested inmates. . . .
[T]he court finds that the logical connection between DPS's decision to not recognize Humanism as a faith group and its stated legitimate policy goals is so remote as to render the policy arbitrary or irrational.
The AHA staff is currently working with community volunteers to facilitate the commencement of Humanist group meetings at Nash Correctional Institution.
Selected Docket Files:
CASE NO. 5:15-ct-03053-F
MARCH 29, 2018
AHA wins monumental victory in prisoners' rights case.
JANUARY 24, 2018
AHLC takes case to Federal Court.
JULY 28, 2017
Defending humanists facing discrimination.
FEBRUARY 26, 2015
The Appignani Humanist Legal Center advocates for a humanist prisoner in North Carolina.