Mobley v. Coleman
2013 Pa. Commw. LEXIS 78
Pa. Commw. Ct.2013Background
- Mobley, an NOI inmate at SCI-Fayette, filed a class action on behalf of NOI inmates challenging prison officials' denial of separate NOI worship services.
- Complaint alleges prison officials compel NOI adherents to participate in Sunni services and to support practices contrary to NOI beliefs.
- Respondents filed preliminary objections arguing no right to separate NOI services, penological reasons support consolidation, no substantial burden on religion, and no RLUIPA/Act violations.
- Court applies Miles factors and related precedent to assess religious accommodation, emphasizing prison discretion and penological interests.
- Court distinguishes between rights to worship and duty to provide services for every religious denomination, noting practical limits and resources.
- Court ultimately sustains the objection to RLUIPA/Act claims but overrules the constitutional claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether lack of separate NOI services violates the U.S. and Pennsylvania Constitutions | Mobley asserts rights to separate NOI services and equal treatment. | Respondents contend legitimate penological interests justify no separate NOI services. | Constitutional claims overruled; no violation found. |
| Whether Mobley states a RLUIPA or Pennsylvania Act claim | Mobley contends substantial burden and discrimination against NOI. | Respondents argue no substantial burden and no statutory violation. | RLUIPA/Act claims sustained; demurrer upheld on those claims. |
| Whether the case can proceed as a class action given pro se status | Mobley seeks class-wide relief on behalf of NOI inmates. | Pro se prisoners may not represent class interests effectively. | Putative class action claims should be dismissed. |
Key Cases Cited
- Miles v. Beard, 847 A.2d 161 (Pa. Cmwlth. 2004) (three-factor test for religious accommodation in prisons)
- DeHart v. Horn, 227 F.3d 47 (3d Cir. 2000) (penological interests and reasonable accommodation framework)
- Overton v. Bazzetta, 539 U.S. 126 (U.S. 2003) (burden on prisoners' rights; State bears burden to disprove regulations)
- Clifton v. Craig, 924 F.2d 182 (10th Cir. 1991) (limits on accommodating every faith group; general policy may be legitimate)
- Gittlemacker v. Prasse, 428 F.2d 1 (3d Cir. 1970) (state not obliged to provide services for every denomination)
- Cruz v. Beto, 405 U.S. 319 (U.S. 1972) (special chapel need not be provided for every faith)
- Turner v. Safley, 482 U.S. 78 (U.S. 1987) (modes to assess prisoners' rights vs. penological interest; four-factor test)
- Smith v. Kyler, 295 Fed.Appx. 479 (3d Cir. 2008) (broader faith group chaplain policy upheld; limited group recognition)