Inmate Christopher Grief, in his second amended complaint filed in February 2016 against Metropolitan Detention Center Brooklyn Warden Herman Quay, alleged violation of the Religious Freedom Restoration Act. Grief stated that, while he “does not belong to any mainstream religion,” his beliefs—stemming from “various religions” such as Buddhism but also “from science and science fiction as well as his life experiences”—lead him to find “spiritual guidance from his stuffed animals during meditation.”
It’s unclear whether this applies for all stuffed animals, like the old-school Gunds, or just the newer ones like Beanie Babies. It’s not entirely clear why stuffed animals are forbidden in prison. Maybe they can be turned into weapons? Maybe fights break out over inmates stealing them? It would seem that a prisoner clinging to his beloved animal could give rise to shower issues. But if a guy gets his spiritual guidance from his teddy, what’s a court to do?
In April 2016, U.S. District Judge Pamela Chen for the Eastern District of New York dismissed with prejudice Grief’s complaint for failure to state a claim. According to Chen, while Grief’s beliefs regarding stuffed animals may be sincere, “they do not, and cannot, demonstrate that these beliefs are religious in nature.”
Quoting from the U.S. Supreme Court’s 1989 opinion in Frazee v. Ill. Dept. of Empl. Sec., Chen said Grief’s beliefs fall “within the category of beliefs that are ‘so bizarre, so clearly nonreligious in motivation, as not to be entitled to protection.’”
This is the thoughtful way in which an experienced district court judge explains, “are you fucking kidding me?” The Second Circuit replied, “No. No we are not.”
In a summary order, the panel said that Chen erred in not determining through fact-finding whether the belief’s professed are religious in nature. The circuit’s precedent in Patrick v. LeFevre allows for a more “subjective definition” that requires an examination of “an individual’s inward attitudes towards a particular belief system” before an RFRA determination can be made.
“Accepting Grief’s allegations as true and construing the complaint in the light most favorable to him, with the special solicitude that we afford to a pro se litigant, we conclude that the district court erred in deciding that Grief’s belief regarding stuffed animals could not plausibly constitute a religious belief, and that the district court therefore erred in dismissing Grief’s RFRA claim at this stage,” the panel stated.
Who would doubt that it’s “plausible” that stuffed animals “constitute a religious belief”?
And so the circuit remanded the case back to EDNY Judge Pamela Chen, raising the only serious question in this case. What did she do to so piss off the circuit that they sent this case back to her?
Attorneys for the U.S. Attorney’s Office for the Eastern District of New York represented the government on appeal. A spokesman for the office declined to comment on the panel’s decision.
They lost to a stuffed animal. This has got to be humiliating.