Inmate Who Can’t Meditate Without Stuffed Animals May Pursue Religious Claim

An appeals court has ruled in favor of a prison inmate who says he needs
stuffed animals in order to practice his religion. Photo: Shutterstock

A federal appeals court has ruled in favor of a prison inmate who said he needs to have stuffed animals in order to meditate. This paves the way for him to pursue a religious claim further.

Christopher Grief, representing himself, had claimed that prison officials’ denial of his wish to have stuffed animals was a violation of the Religious Freedom Restoration Act. Although Grief said that he isn’t part of any mainstream religion, he did say that his spirit guides are animals, and thus, he receives spiritual guidance through stuffed animals during his meditation. He also said he “cannot do any meaningful meditation” without them.

Grief says his beliefs “stem from his understanding of various religions like Buddhism and Native American, and also from science and science fiction.”

U.S. District Court Judge Pamela Chen of the Eastern District of New York had dismissed Grief’s request for failure to state a claim. Chen’s reasoning, according to the appeals court’s ruling, was that Grief’s “belief that stuffed animals are necessary for his religious practice falls within the category of beliefs that are ‘so bizarre, so clearly nonreligious in motivation, as not to be entitled to protection.’”

The summary order, presented by Second Circuit Court of Appeals Chief Judge Robert Katzmann, and Circuit Judges Raymond Loheir, Jr., and Christopher Droney continued, “However, whether a professed belief is entitled to free exercise protection under our precedents requires a determination by the ‘factfinder’ regarding ‘whether the beliefs professed are, in the claimant’s own scheme of things, religious.’ Accepting Grief’s allegations as true and construing the complaint in the light most favorable to him, with the special solicitude that we afford a pro se litigant, we conclude that the district court erred in deciding that Grief’s belief regarding stuffed animal could not plausibly constitute a religious belief, and that the district court therefore erred in dismissing Grief’s RFRA claim at this stage.”

What do you think? Is Grief’s claim frivolous? Is he entitled to protections under the Religious Freedom Restoration Act, or was Judge Chen right in dismissing Grief’s case? Talk about it in the comments!