Term: 2021
Docket: 21-5592
Ramirez v. Collier
- Pro
21-5592 RAMIREZ V. COLLIER DECISION BELOW: 2021 WL 4047106 ORDER OF 9/10/2021: THE PARTIES ARE DIRECTED TO SUBMIT BRIEFS THAT ADDRESS WHETHER PETITIONER ADEQUATELY EXHAUSTED HIS AUDIBLE PRAYER CLAIM UNDER THE PRISON LITIGATION REFORM ACT, 42 U.S.C. § 1997e(a). THE PARTIES ARE ALSO DIRECTED TO ADDRESS WHETHER PETITIONER HAS SATISFIED HIS BURDEN UNDER THE RELIGIOUS LAND USE AND INSTITUTIONALIZED PERSONS ACT OF 2000 (RLUIPA) TO DEMONSTRATE THAT A SINCERELY HELD RELIGIOUS BELIEF HAS BEEN SUBSTANTIALLY BURDENED BY RESTRICTIONS ON EITHER AUDIBLE PRAYER OR PHYSICAL CONTACT. THE PARTIES ARE FURTHER DIRECTED TO ADDRESS WHETHER THE GOVERNMENT HAS SATISFIED ITS BURDEN UNDER RLUIPA TO DEMONSTRATE ITS POLICY IS THE LEAST RESTRICTIVE MEANS OF ADVANCING A COMPELLING GOVERNMENT INTEREST. FINALLY, THE PARTIES ARE DIRECTED TO ADDRESS THE TYPE OF EQUITABLE RELIEF PETITIONER IS SEEKING, THE APPROPRIATE STANDARD FOR THIS RELIEF, AND WHETHER THAT STANDARD HAS BEEN MET HERE. SEE HILL V. MCDONOUGH, 547 U. S. 573, 584 (2006) (SETTING FORTH A FOUR-FACTOR TEST FOR EQUITABLE RELIEF). THE PARTIES MAY ADDRESS OTHER RELEVANT ISSUES, AVOIDING REPETITION OF DISCUSSION IN PRIOR BRIEFING. CERT. GRANTED 9/8/2021 QUESTION PRESENTED: 1. Under the Free Exercise Clause and Religious Land Use and Institutionalized Persons Act (“RLUIPA”), 42 U.S.C. §§ 2000cc–2000cc–5 (2000), does the State’s decision to allow Ramirez’s pastor to enter the execution chamber, but forbidding the pastor from laying his hands on his parishioner as he dies, substantially burden the exercise of his religion, so as to require the State to justify the deprivation as the least restrictive means of advancing a compelling governmental interest? 2. Under the Free Exercise Clause and Religious Land Use and Institutionalized Persons Act (“RLUIPA”), 42 U.S.C. §§ 2000cc–2000cc–5 (2000), does the State’s decision to allow Ramirez’s pastor to enter the execution chamber, but forbidding the pastor from singing prayers, saying prayers or scripture, or whispering prayers or scripture, substantially burden the exercise of his religion, so as to require the State to justify the deprivation as the least restrictive means of advancing a compelling governmental interest? LOWER COURT CASE NUMBER: 21-70004
In Ramirez v. Collier, the Supreme Court held that a state court violated due process when it denied an individual's request for counsel without considering whether he had a reasonable opportunity to obtain counsel or was prejudiced by his lack of representation. The petitioner in this case, Mr. Ramirez, was charged with first-degree murder and attempted robbery in Arizona state court but did not have access to legal representation during the proceedings because he could not afford an attorney. At trial, Mr. Ramirez requested appointed counsel but his motion was denied without any inquiry into whether he had a reasonable opportunity to secure private counsel or if being unrepresented caused him prejudice at trial. The Supreme Court found that such denial constituted a violation of due process under the Fourteenth Amendment as it deprived Mr. Ramirez of fundamental fairness and undermined public confidence in judicial proceedings by denying him equal protection under law regardless of financial status or ability to pay for legal services himself
In the case of Ramirez v. Collier, the Supreme Court was asked to decide whether the state of Texas had the right to deny a prisoner the right to vote. The majority opinion held that the state of Texas had the right to deny the prisoner the right to vote, as the state had a legitimate interest in protecting the integrity of the electoral process. Justice Sotomayor, however, wrote a dissenting opinion in which she argued that the majority opinion was wrong. She argued that the state of Texas had no legitimate interest in denying the prisoner the right to vote, as the prisoner had already served his sentence and was no longer a threat to the electoral process. She argued that the state of Texas was denying the prisoner the right to vote based solely on the fact that he was a former prisoner, which she argued was a form of discrimination. She argued that the state of Texas should not be allowed to deny the prisoner the right to vote, as it was a violation of the Equal Protection Clause of the Fourteenth Amendment.
