Ramirez v. Collier, 595 U.S. 411

Ramirez was sentenced to death in Texas for a 2004 murder; execution was set for Sept. 8, 2021 after years of litigation.
Texas amended its execution protocol to allow a condemned prisoner’s spiritual advisor into the execution chamber but (according to officials) did not permit the advisor to touch the inmate or pray audibly.
Ramirez filed prison grievances requesting that his pastor be permitted to “lay hands” on him and to pray aloud during the execution; Texas denied the touching request and did not expressly allow audible prayer.
Ramirez sued under RLUIPA and §1983, sought a preliminary injunction to require Texas to permit audible prayer and limited touch during his execution, and sought a stay; lower courts denied relief, this Court stayed the execution and granted certiorari.
The Supreme Court held Ramirez likely to succeed on his RLUIPA claims because Texas’s categorical bans on audible prayer and religious touch impose substantial burdens and are not shown to be the least restrictive means of furthering the State’s asserted compelling interests.
The Court directed that tailored injunctive relief (not a blanket stay) is the appropriate remedy where accommodation is feasible and urged States to adopt clearer, expedited procedures for resolving such requests in the execution context.

Issue	Plaintiff's Argument (Ramirez)	Defendant's Argument (Texas)	Held
PLRA exhaustion	Ramirez exhausted Texas grievance process (Step 1 and timely Step 2) before filing suit	Ramirez failed to exhaust (filed suit before Step 2 decision; grievances didn’t explicitly request "audible" prayer; filed late)	Court: Ramirez exhausted for current posture; grievances reasonably conveyed requests and were timely
RLUIPA sincerity/substantial burden	Requests (laying on of hands; audible prayer) are sincerely religious and substantially burdened if barred	Government disputes sincerity based on prior filings that disclaimed touching	Court: Ramirez likely sincere; burden conceded by respondents is substantial
Least restrictive means — audible prayer	Categorical ban unnecessary; less restrictive measures (volume limits, silence at critical moments, removal for disruption) suffice	Absolute silence needed to monitor inmate via mic and prevent statements to witnesses	Court: Texas failed to show categorical ban is least restrictive; history and other jurisdictions’ accommodations persuasive
Least restrictive means — religious touch	Limited touch (e.g., foot/leg away from IV) and precautions can mitigate risks to security/medical integrity	Touch risks escape, weapon, IV tampering, increased suffering, trauma to victims’ families; categorical ban needed	Court: Texas did not prove ban is least restrictive; offered no adequate, case-specific tailoring or alternatives rebuttal

Winter v. Natural Resources Defense Council, 555 U.S. 7 (U.S. 2008) (standard for preliminary injunction factors)
Holt v. Hobbs, 574 U.S. 352 (U.S. 2015) (RLUIPA: plaintiff must show sincerity and substantial burden; once shown, government must show least restrictive means)
Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418 (U.S. 2006) (burden allocation in preliminary injunction/RFRA context)
Woodford v. Ngo, 548 U.S. 81 (U.S. 2006) (PLRA requires proper exhaustion of administrative remedies)
Ross v. Blake, 578 U.S. 632 (U.S. 2016) (administrative remedies are excused when not "available")
Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (U.S. 2014) (government cannot rely on broadly formulated interests to satisfy strict scrutiny)
Cutter v. Wilkinson, 544 U.S. 709 (U.S. 2005) (RLUIPA interpretation and application to institutionalized persons)
Hill v. McDonough, 547 U.S. 573 (U.S. 2006) (importance of timely enforcement of a death sentence in equitable balancing)
Nken v. Holder, 556 U.S. 418 (U.S. 2009) (stay/injunction equitable analysis)
Keystone Driller Co. v. General Excavator Co., 290 U.S. 240 (U.S. 1933) (equitable defense: misconduct can bar equitable relief)