Ramirez v. Collier

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Supreme Court of the United States
Ramirez v. Collier
Term: 2021
Important Dates
Argued: November 9, 2021
Decided: March 24, 2022
Outcome
Reversed and remanded
Vote
8-1
Majority
Chief Justice John Roberts • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Concurring
Sonia Sotomayor • Brett Kavanaugh
Dissenting
Clarence Thomas

Ramirez v. Collier is a case decided by the Supreme Court of the United States on March 24, 2022, during the court's October 2021-2022 term. The case was argued before the court on November 9, 2021. The court reversed and remanded the decision of the U.S. Court of Appeals for the 5th Circuit, holding (1) Ramirez filed timely grievances as part of the Texas prison grievance process before filing suit against the State of Texas and (2) Ramirez is likely to succeed on his claims under the RLUIPA. Chief Justice John Roberts wrote the majority opinion. Justices Sonia Sotomayor and Brett Kavanaugh filed concurring opinions. Justice Clarence Thomas filed a dissenting opinion. Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned the aid a spiritual advisor is permitted to provide during an execution.[1] Click here to learn more about the case's background.
  • The questions 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?"[2][3]
  • The outcome: The court reversed and remanded the decision of the U.S. Court of Appeals for the 5th Circuit, holding (1) Ramirez filed timely grievances as part of the Texas prison grievance process before filing suit against the State of Texas and (2) Ramirez is likely to succeed on his claims under the RLUIPA.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 5th Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • March 24, 2022: The U.S. Supreme Court reversed and remanded the U.S. Court of Appeals for the 5th Circuit's ruling.
    • November 9, 2021: The U.S. Supreme Court heard oral argument. The case was originally scheduled for argument on November 1, 2021.
    • September 8, 2021: The U.S. Supreme Court agreed to hear the case.
    • September 7, 2021: John Ramirez appealed to the U.S. Supreme Court.
    • September 6, 2021: The U.S. Court of Appeals for the 5th Circuit denied the motion for a stay of execution.

    Background

    In 2008, John Ramirez was convicted of the 2004 murder of Pablo Castro in Nueces County, Texas and was sentenced to death. The Texas Court of Criminal Appeals affirmed the conviction and sentencing on appeal. In 2012, the state court denied Ramirez's request for post-conviction relief filed with the trial court after an evidentiary hearing and the trial court's report and recommendation. In 2012, Ramirez filed a petition for a writ of habeas corpus with the U.S. District Court for the Southern District of Texas. The court denied the request for relief and a certificate of appealability. Ramirez filed a notice of appeal with the U.S. Court of Appeals for the 5th Circuit in 2016, and the federal circuit court denied the request for a certificate of appealability. Also that year, the U.S. Supreme Court denied Ramirez's petition for certiorari review.[3]

    The State of Texas scheduled Ramirez's execution date for February 2, 2017. In January of that year, Ramirez moved to stay, or postpone, the execution date while he made a legal counsel substitution. The U.S. district court granted the motion. In 2018, Ramirez filed a motion for relief from judgment with the court, which was denied. On appeal in 2019, the 5th Circuit denied his request to file an appeal. In March 2020, the U.S. Supreme Court denied review of the case.[3]

    The state set a new execution date for September 9, 2020. In August of that year, Ramirez filed a spiritual advisory claim in a civil action against the state. Ramirez and state officials reached an agreement to withdraw the execution date in exchange for Ramirez's agreement not to sue without prejudice and to dismiss a funding request.[3]

    A new execution date was scheduled for September 8, 2021. On August 10, 2021, Ramirez filed a new spiritual advisory claim requesting to have his pastor be permitted to pray aloud and physically touch him in the execution chamber while the sentence was carried out, citing the Religious Land Use and Institutionalized Persons Act of 2000. The State of Texas refused the request. On August 18, Ramirez filed a motion for a stay of execution with the U.S. district court, which the court denied on September 2. On September 6, the 5th Circuit affirmed the district court's ruling on appeal. On September 7, Ramirez filed an emergency appeal with the U.S. Supreme Court to postpone the execution and to hear arguments in his case on the merits. He argued that the state's denial of his request was a violation of his constitutional rights and of federal protections for inmates' religious rights. The state argued that it did not force Ramirez to violate his religion, however, it declined to accommodate all of his religious needs. On September 8, SCOTUS granted Ramirez's application for a stay of execution and granted a petition for a writ of certiorari to hear arguments in the case on its merits docket during the 2021-2022 term.[3][4][5][6][7]

    Religious Land Use and Institutionalized Persons Act of 2000

    The Religious Land Use and Institutionalized Persons Act of 2000 provides:[8]

    “ ... RLUIPA prohibits zoning and landmarking laws that substantially burden the religious exercise of churches or other religious assemblies or institutions absent the least restrictive means of furthering a compelling governmental interest. This prohibition applies in any situation where: (i) the state or local government entity imposing the substantial burden receives federal funding; (ii) the substantial burden affects, or removal of the substantial burden would affect, interstate commerce; or (iii) the substantial burden arises from the state or local government's formal or informal procedures for making individualized assessments of a property's uses. In addition, RLUIPA prohibits zoning and landmarking laws that:
    1. treat churches or other religious assemblies or institutions on less than equal terms with nonreligious assemblies or institutions;
    2. discriminate against any assemblies or institutions on the basis of religion or religious denomination;
    3. totally exclude religious assemblies from a jurisdiction; or
    4. unreasonably limit religious assemblies, institutions, or structures within a jurisdiction.[9]
    		 ”

    Questions presented

    The petitioner presented the following questions to the court:[3]

    Questions 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?[9]
    		 ”

    Oral argument

    The U.S. Supreme Court heard oral argument on November 9, 2021. The case was originally scheduled for argument on November 1, 2021.

    Audio

    Audio of oral argument:[10]



    Transcript

    Transcript of oral argument:[11]

    Outcome

    In an 8-1 opinion, the court reversed and remanded the judgment of the U.S. 5th Circuit Court of Appeals, holding (1) Ramirez filed timely grievances as part of the Texas prison grievance process before filing suit against the State of Texas and (2) Ramirez is likely to succeed on his claims under the RLUIPA. Chief Justice Roberts delivered the opinion of the court. Justices Sotomayor and Kavanaugh filed concurring opinions. Justice Thomas dissented.[12]

    Opinion

    In the court's majority opinion, Chief Justice Roberts wrote:[12]

    “ The prison officials begin by arguing that Ramirez cannot hope to succeed on his claims, because he failed to exhaust all available remedies before filing suit. ... Thus, if Ramirez failed to exhaust all available administrative remedies, his suit may not proceed. Respondents argue that is the case here. We disagree. ,,, We thus have little trouble concluding that the grievance was timely, and that we may proceed to the merits. ...


    We conclude that Ramirez is likely to prevail on his claim that Texas’s categorical ban on religious touch in the execution chamber is inconsistent with his rights under RLUIPA. ... Ramirez is likely to suffer irreparable harm in the absence of injunctive relief because he will be unable to engage in protected religious exercise in the final moments of his life. ... Because it is possible to accommodate Ramirez’s sincere religious beliefs without delaying or impeding his execution, we conclude that the balance of equities and the public interest favor his requested relief. ...

    We hold that Ramirez is likely to prevail on the merits of his RLUIPA claims, and that the other preliminary injunction factors justify relief. If Texas reschedules Ramirez’s execution and declines to permit audible prayer or religious touch, the District Court should therefore enter appropriate preliminary relief.[9]

    		”
    —Chief Justice John Roberts

    Concurring opinion

    Justices Sotomayor and Kavanaugh filed concurring opinions.

    In her concurring opinion, Justice Sotomayor wrote:[12]

    “ I write separately to underscore the interaction between prison officials’ obligations to set such rules and the exhaustion requirement of the Prison Litigation Reform Act (PLRA). ... At its heart, the Religious Land Use and Institutionalized Persons Act requires commitment on both sides to achieve a timely resolution of disputes, as does the PLRA’s exhaustion requirement. Consistent with these principles, incarcerated individuals should know that delays in raising their requests can result in denial. They should not, however, be penalized for delays attributable to prison administrators.[9] ”
    —Justice Sonia Sotomayor

    In his concurring opinion, Justice Kavanaugh wrote:[12]

    “ [T]he compelling interest and least restrictive means standards require this Court to make difficult judgments about the strength of the State’s interests and whether those interests can be satisfied in other ways that are less restrictive of religious exercise. Although the compelling interest and least restrictive means standards are necessarily imprecise, history and state practice can at least help structure the inquiry and focus the Court’s assessment of the State’s arguments.[9] ”
    —Justice Brett Kavanaugh

    Dissenting opinion

    Justice Thomas filed a dissenting opinion.

    In his dissent, Justice Thomas wrote:[12]

    “ Because I think Ramirez’s claims either do not warrant equitable relief or are procedurally barred, I respectfully dissent. ... Ramirez presses two reasons why he merited—and continues to merit—our intervention in Texas’ enforcement of his capital sentence. ... I do not think either claim warranted relief on [when the U.S. Supreme Court agreed to hear the case]. Nor do I think either claim warrants further relief now. ...


    Today, this Court should have denied equitable relief to a prisoner who has acted inequitably—as both the District Court and Court of Appeals did before us. Ramirez’s shifting litigation position lays bare what he really wants: “to manipulate the judicial process” to win further delay. ...

    [The Court] grants equitable relief for a demonstrably abusive and insincere claim filed by a prisoner with an established history of seeking unjustified delay, harming the State and Ramirez’s victims in the process. The Court also forgives the same prisoner’s complete failure to exhaust another claim. Because I would deny equitable relief for the first claim and dismiss the second under the PLRA, I respectfully dissent. [9]

    		”
    —Justice Clarnece Thomas

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[13]

    The court agreed to hear 68 cases during its 2021-2022 term.[14] Four cases were dismissed and one case was removed from the argument calendar.[15]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ SCOTUSblog, "Court blocks execution, will weigh in on inmate’s religious-liberty claims," September 8, 2021
    2. ↑ U.S. Supreme Court, "Ramirez v. Collier: Questions presented," accessed September 9, 2021
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 U.S. Supreme Court, "Ramirez v. Collier: Petition for a writ of certiorari," accessed September 9, 2021
    4. ↑ U.S. Supreme Court, "(ORDER LIST: 594 U.S.) CERTIORARI GRANTED, 21-5592 RAMIREZ, JOHN H. V. COLLIER, BRYAN, ET AL.," September 8, 2021
    5. ↑ U.S. Supreme Court, "No. 21-5592 *** CAPITAL CASE ***," accessed September 9, 2021
    6. ↑ SCOTUSblog, "Court blocks execution, will weigh in on inmate’s religious-liberty claims," September 8, 2021
    7. ↑ SCOTUSblog, "Ramirez v. Collier," accessed September 9, 2021
    8. ↑ U.S. Department of Justice, "Religious Land Use And Institutionalized Persons Act," accessed September 9, 2021
    9. ↑ 9.0 9.1 9.2 9.3 9.4 9.5 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    10. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued November 9, 2021
    11. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued November 9, 2021
    12. ↑ 12.0 12.1 12.2 12.3 12.4 Supreme Court of the United States, Ramirez v. Collier, decided March 24, 2022
    13. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    14. ↑ Consolidated cases are counted as one case for purposes of this number.
    15. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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