LaPlante v. Massachusetts Department of Correction
89 F. Supp. 3d 235
D. Mass.2015Background
- LaPlante, a prisoner at MCI-Norfolk, sues the DOC and its superintendent under RLUIPA seeking declaratory and injunctive relief for burdens on his Wicca practice.
- Procedural history: LaPlante filed March 14, 2013; cross-motions for summary judgment; initial denial of his first MSJ; renewed MSJ and responses in May 2014.
- DOC provides SOC accommodations for Wicca via a Handbook and a committee process; LaPlante sought accommodations not explicitly listed in the Handbook.
- Wicca has been practiced at MCI-Norfolk since at least 1985; the DOC hosts a CSD worship space for up to 250 inmates with various ritual items.
- Legal framework: the court applies RLUIPA’s substantial-burden and compelling-interest standards; cross-motions are evaluated separately and with deference to prison expertise.
- Disposition: the court grants and denies in part LaPlante’s and the DOC’s motions on multiple items, and the case is set for a jury-waived trial on factual disputes on the May 2015 list.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Sunday worship schedule substantial burdens Wiccan practice. | LaPlante argues the schedule prevents worship on moon-phase days. | Roden/DOC argue the schedule is a permissible accommodation. | Substantial burden found; schedule constitutes a substantial burden. |
| Whether restricting ritual oils to four types is a substantial burden. | LaPlante proves lack of oils impairs essential rites. | Limit is necessary for security and logistics. | Disputed facts; summary judgment denied for both sides. |
| Whether access to ritual herbs is a substantial burden. | LaPlante claims herbs are essential to practice. | Storage, cost, toxicity, and administrative burdens justify limit. | Disputed facts; summary judgment denied for both sides. |
| Whether access to ritual teas is a substantial burden. | Teas are essential for certain rites. | Limit necessary for security/logistics; storage concerns. | Disputed facts; summary judgment denied for both sides. |
| Whether outdoor worship is permitted and constitutes a substantial burden. | Wiccans must perform Earth Offerings outdoors. | Security and staffing concerns; no outdoor space or supervision. | Disputed facts; summary judgment denied for both sides. |
| Whether access to fruits and nuts for communal offerings is a substantial burden. | Denial prevents proper offering and worship. | Helps prevent homebrew and storage issues. | LaPlante granted on this point; substantial burden established. |
Key Cases Cited
- Holt v. Hobbs, 135 S. Ct. 853 (2015) (RLUIPA/Hobby Lobby scrutiny; robust burden analysis in prison context)
- Lyng v. Northwest Indian Cemetery Protective Ass’n, 485 U.S. 439 (1988) (incidental effects not a substantial burden; coercion standard guidance)
- LeBaron v. Spencer, 527 Fed.Appx. 25 (1st Cir. 2013) (functional, case-specific analysis of substantial burden in RL UIPA context)
- Couch v. Jabe, 479 F. Supp. 2d 569 (W.D. Va. 2006) (substantial burden when worship is displaced from religiously mandated timing)
- Rasheed v. Comm’r of Correction, 446 Mass. 463 (2006) (Mass. high court on limits of prayer-oil restrictions and religious exercise)
- Hammons v. Saffle, 348 F.3d 1250 (10th Cir. 2003) (First Amendment context; limitations on oils analyzed under narrower standard)