PRISON

Holt v. Hobbs

Issues

Does a prison’s grooming policy, which prohibits all beards except for quarter-inch beards for certain medical reasons, violate the Religious Land Use and Institutionalized Persons Act by prohibiting an inmate from growing a half-inch beard in accordance with his religious beliefs?

In 2000, Congress enacted the Religious Land Use and Institutionalized Persons Act (“RLUIPA”) with the intent to provide protection for the free exercise of religion in various contexts, including prisons and jails. In this case, the Supreme Court will consider whether a prison grooming policy prohibiting a half-inch beard grown in accordance with a prisoner’s religious beliefs, violates RLUIPA. Additionally, the Court will have the opportunity to determine the level of deference courts should give prison officials when considering whether a prison policy that substantially burdens inmates’ exercise of religion furthers a compelling governmental interest and is the least restrictive means available. The resolution of this case may impact the balance between the rights of prisoners to practice their religion freely while incarcerated and the government’s interest in prison safety. 

Questions as Framed for the Court by the Parties

  1. Whether the Arkansas Department of Corrections’ no beard grooming policy violates the Religious Land Use and Institutionalized Persons Act (RLUIPA).
  2. Whether a ½ inch beard would satisfy the security goals sought by the policy.
  3. Whether the no beard grooming policy violates Petitioner’s First Amendment right to practice Islam as he believes it is supposed to be practiced by the wearing of the beard.
  4. That the United States Court of Appeals for the Eighth Circuit has decided that the no beard grooming policy does not violate the RLUIPA, but this Court should decide the matter since it has not done so and should rule whether grooming policies of any Department of Correction that do not allow for a religious exception exemption are constitutional.
  5. That the United States Court of Appeals for the Eighth Circuit’s decision in this case conflicts with other circuit’s rulings on the matter.
  6. That the ADC grooming policy of no beards is not the least restrictive means of achieving the desired objective of staunching the flow of contraband and identifying prisoners in the event of an escape.

In 2000, Congress enacted the Religious Land Use and Institutionalized Persons Act (“RLUIPA”) to provide protection for the free exercise of religion in several contexts, including incarceration. See 42 U.S.C.

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Jones v. Hendrix

Issues

Does a prisoner who did not initially challenge certain aspects of their conviction have the right to challenge their conviction later via habeas corpus after the Supreme Court changed the standard of conviction for the related crime?

This case asks the Supreme Court to determine the extent to which habeas relief is available to a prisoner after a Supreme Court case heightens the standard of conviction for the crime they were convicted of. The relevant statutory provision, 28 U.S.C. § 2255(e)’s saving clause, allows a prisoner to move for habeas relief if alternative remedies available under other subsections of § 2255 are “inadequate or ineffective to test the legality of [their] detention.” Petitioner Marcus DeAngelo Jones argues that because the lower court applied the wrong substantive law, the alternative remedies were ineffective in testing the legality of his detention, and that he is therefore entitled to habeas relief under § 2255(e). Jones further argues that the Eighth Circuit’s interpretation of the statute renders § 2255(e) superfluous and violates many of Jones’s constitutional rights. Respondent Dewayne Hendrix counters that the § 2255(e) requires a showing of actual innocence, which he argues Jones cannot make, in order to trigger habeas relief, and that Jones’ constitutional concerns are misguided. The outcome of this case will determine the availability of post-conviction relief to prisoners following changes in relevant substantive law.

Questions as Framed for the Court by the Parties

Whether federal inmates who did not — because established circuit precedent stood firmly against them — challenge their convictions on the ground that the statute of conviction did not criminalize their activity may apply for habeas relief under 28 U.S.C § 2241 after the Supreme Court later makes clear in a retroactively applicable decision that the circuit precedent was wrong and that they are legally innocent of the crime of conviction.

In December 1999, Marcus DeAngelo Jones was arrested at a convenience store in Columbia, Missouri as part of an undercover operation related to drug dealing. U.S. v. Jones at 808. At trial, the government introduced evidence showing that Jones had been in possession of a firearm on multiple occasions. Id. Jones possessed this firearm despite his several prior felony convictions.

Acknowledgments

The authors would like to thank Professor John Blume for his guidance and insights into this case.

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Kingsley v. Hendrickson

Issues

Does a pretrial detainee need to show that a state actor applied force recklessly and acted with reckless disregard for his or her rights?

In this case, the Supreme Court will decide whether a pretrial detainee’s § 1983 excessive force claim requires a showing that the force used by the state actor was objectively unreasonable and that the use of force was deliberate. Petitioner, Michael Kingsley, argues that an excessive force claim brought by a pretrial detainee requires only a showing that the force used was objectively unreasonable. Respondents, represented by Stan Hendrickson, argue that an excessive force claim brought by a pretrial detainee requires a showing of the state actor’s subjective intent to be reckless or deliberate. The Court’s decision will impact the means by which pretrial detainees bring excessive-force claims and the policies that govern prisons.

Questions as Framed for the Court by the Parties

Whether the requirements of a 42 U.S.C. § 1983 excessive force claim are satisfied per se by a showing that the state actor deliberately used force against the pretrial detainee and the use of force was objectively unreasonable.

On May 20, 2010, a deputy performing a cell check ordered Michael Kingsley, a pretrial detainee at Monroe County Jail, to take down a piece of paper covering the light above his cell bed. Kingsley v. Hendrickson, 744 F.3d 443, 445 (7th Cir. 2013). Kingsley refused to do so.

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Mathis v. United States

Issues

How should sentencing courts determine whether a defendant has satisfied the predicate felonies necessary to mandate a higher minimum sentence under the Armed Career Criminal Act?

 

The Supreme Court will decide how a sentencing court using the “modified categorical approach” should determine if a defendant felon has satisfied the predicate felonies necessary to mandate a higher minimum sentence under the Armed Career Criminal Act (“ACCA”). Mathis argues that the “modified categorical approach” can be based only on the text of the state criminal statute as well as state court analysis of its elements, without regard to the court record or the means necessary to accomplish an element. The United States contends that the standard is simply that criminal statutes phrased in the disjunctive are divisible and that courts may then use court documents under the “modified categorical approach” to determine if the defendant was convicted of the generic crime. This decision will impact the severity of prison terms for many prior felons and has great repercussions for noncitizen felons. 

Questions as Framed for the Court by the Parties

Must a predicate prior conviction under the Armed Career Criminal Act, 18 U.S.C. § 924(e)(1), qualify as such under the elements of the offense simpliciter, without extending the modified categorical approach to separate statutory definitional provisions that merely establish the means by which referenced elements may be satisfied rather than stating alternative elements or versions of the offense?

In March 2013, Richard Mathis (“Mathis”) was accused of forcibly molesting a teenage boy. See United States v. Richard Mathis, 786 F.3d 1068, 1070 (8th Cir.

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Rosales-Mireles V. United States

Issues

Should the Supreme Court correct a sentencing error where a prisoner’s criminal history is miscalculated, but the imposed sentence falls within the U.S. Sentencing Guidelines’ range?

To aid the courts in sentencing defendants, the U.S. Sentencing Guidelines recommend prison sentences based on defendants’ criminal histories. When a probation officer miscalculated convicted defendant Rosales-Mireles’s criminal history, the error bumped Rosales-Mireles into a sentencing category with a longer recommended imprisonment range. However, he ultimately received a sentence that overlapped with the range of the appropriate sentencing category. Rosales-Mireles contends that allowing such plain errors in criminal history calculations damages the fairness of the judicial process, and undermines the Guidelines’ purpose of uniform sentencing. The Government counters that requiring remand would erode courts’ discretion and impose a heavy financial burden on the Government. The Court must decide if integrity of the judiciary is better preserved by correcting a sentencing error or adhering to standard criminal procedure.

Questions as Framed for the Court by the Parties

Whether, in order to meet the standard for plain error review set forth by the Supreme Court in United States v. Olano that "[t]he Court of Appeals should correct a plain forfeited error affecting substantial rights if the error ‘seriously affect[s] the fairness, integrity, or public reputation of judicial proceedings,’” it is necessary, as the U.S. Court of Appeals for the 5th Circuit required, that the error be one that “would shock the conscience of the common man, serve as a powerful indictment against our system of justice, or seriously call into question the competence or integrity of the district judge.”

In January 2010, Florencio Rosales-Mireles, a Mexican citizen, was convicted of aggravated assault in Texas state court, and was subsequently sent back to Mexico. Brief for Respondent, United States of America at 4. In 2015, after illegally reentering the United States, Rosales-Mireles was again arrested in Texas.

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