Mayweathers v. Newland

314 F.3d 1062, 2002 WL 31875409
CourtCourt of Appeals for the Ninth Circuit
DecidedDecember 27, 2002
DocketNos. 01-16505, 01-16607, 01-17133
StatusPublished
Cited by85 cases

This text of 314 F.3d 1062 (Mayweathers v. Newland) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mayweathers v. Newland, 314 F.3d 1062, 2002 WL 31875409 (9th Cir. 2002).

Opinion

OPINION

D.W. NELSON, Senior Circuit Judge.

California State prison officials (“California”) bring a facial challenge to the constitutionality of the Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C. § 2000cc et seq. (2000) (“RLUI-PA”), on various grounds. Their appeal arises from a series of preliminary injunctions, issued pursuant to RLUIPA, which allow Muslim prisoners to attend Friday afternoon religious services.

The district court upheld the statute as a constitutional exercise of Congress’s Spending Clause authority. We affirm.1

I. FACTUAL AND PROCEDURAL BACKGROUND

RLUIPA protects prisoners and other institutionalized people from government infringement on their practice of religion. Specifically, the statute prescribes that “[n]o government shall impose a substantial burden on the religious exercise” of prisoners unless the government can demonstrate that the burden both serves a compelling government interest and is the least restrictive means of advancing that interest. 42 U.S.C. § 2000cc-l(a) (2000).

A class of Muslim inmates imprisoned at Solano in California originally filed suit in 1996 against various officials of the California State prison system. They alleged [1066]*1066that prison rules penalizing attendance at Friday afternoon religious services, called Jumu’ah, violated the First Amendment. They added a RLUIPA claim following its enactment in 2000.

California moved to dismiss the RLUI-PA claim, arguing that the statute exceeded Congressional authority under the Spending Clause, the Commerce Clause, and the Fourteenth Amendment. California also attacked the statute as violative of the Establishment Clause of the First Amendment, the Tenth and Eleventh Amendments, and the principle of separation of powers. The United States intervened to defend RLUIPA as constitutional.

In a series of separate but related rulings, the district court upheld the constitutionality of RLUIPA, denied California’s motion to dismiss, and granted the prisoners various preliminary injunctions. These injunctions barred prison officials from punishing prisoners for attending Jumu’ah services and prohibited officials from withholding good time credits from inmates who participated in Jumu’ah while this case proceeds.

II. STANDARD OF REVIEW

We review the constitutionality of a statute de novo. Eunique v. Powell, 302 F.3d 971, 973 (9th Cir.2002).

III. The Spending Clause

The Spending Clause allows Congress to further its policy objectives by conditioning the receipt of federal funds on compliance with federal mandates. See South Dakota v. Dole, 483 U.S. 203, 206, 107 S.Ct. 2793, 97 L.Ed.2d 171 (1987). This power is not limitless, however. A statute properly passed under the Spending Clause must meet certain requirements. First, the statute must be in pursuit of the general welfare. Id. at 207, 107 S.Ct. 2793. Second, any conditions on federal grants must be unambiguous, clearly communicating to states the consequences of their participation in the federally funded scheme. Id. Third, the Supreme Court has suggested that conditional federal grants “might be illegitimate if they are unrelated to the federal interest in particular national projects or programs.” Id. (internal quotations and citation omitted) (emphasis added). Finally, other constitutional provisions may provide independent grounds for invalidating an otherwise proper exercise of Congress’s Spending Clause authority. Id. at 208. RLUIPA meets all of these requirements, and the statute is a legitimate exercise of Congressional spending power.

A. Promoting the General Welfare

Congress possesses great leeway to determine which statutory aims advance the general welfare. The Supreme Court has made it clear that “[w]hen money is spent to promote the general welfare, the concept of welfare or the opposite is shaped by Congress.... ” Helvering v. Davis, 301 U.S. 619, 645, 57 S.Ct. 904, 81 L.Ed. 1307 (1937). The Court, in the leading case on Spending Clause authority, reaffirmed that federal courts must “defer substantially” to Congress in determining if a statute advances the general welfare. Dole, 483 U.S. at 207, 107 S.Ct. 2793. In fact, the Court seems doubtful that failure to advance the general welfare could ever provide adequate grounds for invalidating a federal statute. Id. at 207 n. 2, 107 S.Ct. 2793.

In any event, protecting religious worship in institutions from substantial and illegitimate burdens does promote the general welfare. The First Amendment, by prohibiting laws that proscribe the free exercise of religion, demonstrates the great value placed on protecting religious worship from impermissible government [1067]*1067intrusion. By ensuring that governments do not act to burden the exercise of religion in institutions, RLUIPA is clearly in line with this positive constitutional value. Moreover, by fostering non-discrimination, RLUIPA follows a long tradition of federal legislation designed to guard against unfair bias and infringement on fundamental freedoms. See, e.g., Title VI, 42 U.S.C. § 2000d et seq. (2002); Title VII, 42 U.S.C. § 2000e et seq. (2002); Title IX, 20 U.S.C. § 1681 (2002). No sound reason exists to disturb Congress’s finding that RLUIPA promotes the general welfare.

B. Unambiguous Condition

RLUIPA unequivocally states that it applies to any “program or activity that receives Federal financial assistance.” 42 U.S.C. § 2000cc-l(b)(l). A spending power statute, as unambiguous in its conditional language as RLUIPA, ensures that the statute’s intention to impose a condition is expressed clearly. By its plain language, RLUIPA clearly communicates that any institution receiving federal funds must not substantially burden the exercise of religion absent a showing that the burden is the least restrictive means of serving a compelling government interest. The fact that the least restrictive means standard is perhaps unpredictable because it has resulted in different determinations in different courts does not weaken the express conditional language. In fact, the Supreme Court has held that conditions may be “largely indeterminate,” so long as the statute “provid[es] clear notice to the States that they, by accepting funds under the Act, would indeed be obligated to comply with[the conditions].” Pennhurst State School and Hospital v.

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Cite This Page — Counsel Stack

Bluebook (online)
314 F.3d 1062, 2002 WL 31875409, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mayweathers-v-newland-ca9-2002.