Green Haven Prison Preparative Meeting v. New York State Dept. of, 16 F.4th 67

Background

Green Haven Quaker worship group (Green Haven Meeting) held regular meetings: weekly study/worship and Saturday “meetings for worship with a concern for business” (MFWCBs), plus quarterly all-day Quarterly Meetings attended by outside Quakers for ~35 years.
After 2014 security breaches, DOCCS/Green Haven administrators rescheduled Quarterly Meetings from Saturdays to Friday evenings (2015) and curtailed or revoked some Saturday inmate call-outs (including MFWCBs) citing staffing, overtime, out-count and overcrowding concerns.
Plaintiffs: two incarcerated Quakers (Johnson, Thompson), Green Haven Meeting, and non-incarcerated Quaker organizations/individuals, sued under RLUIPA, Free Exercise, Establishment, Equal Protection, and state law; they sought a preliminary injunction to restore prior meeting times.
The district court found irreparable harm but denied the preliminary injunction: incarcerated plaintiffs failed to exhaust administrative remedies (PLRA) and plaintiffs did not show a substantial burden on religious exercise.
On appeal, the Second Circuit affirmed: (1) non-incarcerated plaintiffs have Article III standing to challenge changes affecting Quarterly Meetings; (2) incarcerated plaintiffs’ RLUIPA claims fail for lack of PLRA exhaustion; and (3) plaintiffs were unlikely to show a constitutionally substantial burden given penological justifications and available alternatives.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing of Non‑Incarcerated Plaintiffs and Green Haven Meeting	Non‑incarcerated orgs and Green Haven Meeting have associational/Article III standing to challenge scheduling and calendar designation	Defendants largely did not contest Article III standing for those injuries; argued statutory limits on RLUIPA scope	Non‑incarcerated plaintiffs have standing to challenge Quarterly Meetings scheduling; Green Haven Meeting and incarcerated individuals have standing to challenge policies generally
PLRA exhaustion by incarcerated plaintiffs	Exhaustion not required because grievance process allegedly unavailable for class‑type claims or would be futile	PLRA requires proper exhaustion; DOCCS IGP was available and prison members could file individual grievances	Incarcerated plaintiffs failed to exhaust; PLRA exhaustion applies and bars their RLUIPA claims
Substantial burden under Free Exercise / RLUIPA (scheduling changes to Quarterly Meetings and MFWCBs)	Moving/canceling Saturday meetings (shortening meetings, eliminating meals, reducing attendance) imposes a substantial religious burden on Quaker practice	Scheduling changes are security‑driven, reasonable, provide alternatives (weekday evenings, at least one special event), and do not target religion	Plaintiffs did not show a likelihood of proving a substantial burden; scheduling inconveniences lacked demonstrated religious significance and defendants articulated legitimate penological interests
Preliminary injunction / balance of equities & public interest	First Amendment injury is irreparable; injunction needed to prevent ongoing religious deprivation	Injunction would disrupt institutional security, staffing, and resource allocation; PLRA limits injunctive relief	Irreparable harm established but balance/public interest and narrow PLRA injunction standards weigh against relief; denial of preliminary injunction affirmed

Key Cases Cited

Woodford v. Ngo, 548 U.S. 81 (2006) (exhaustion requires compliance with agency procedural rules)
Ross v. Blake, 136 S. Ct. 1850 (2016) (administrative remedies are ‘‘available’’ if there is a possibility of some relief)
Turner v. Safley, 482 U.S. 78 (1987) (prison regulations that impinge constitutional rights are valid if reasonably related to legitimate penological interests)
O'Lone v. Estate of Shabazz, 482 U.S. 342 (1987) (prisoner free‑exercise claims reviewed under a reasonableness test sensitive to penological concerns)
Salahuddin v. Goord, 467 F.3d 263 (2d Cir. 2006) (four‑factor test for reasonableness of prison restrictions on religious exercise)
Elrod v. Burns, 427 U.S. 347 (1976) (loss of First Amendment freedoms constitutes irreparable injury)
Amador v. Andrews, 655 F.3d 89 (2d Cir. 2011) (proper exhaustion requires using all steps the agency provides)