Brown v. Johnson

• Jurisdiction: United States

Brown v. Johnson

743 F.2d 408 (1984)

Facts

State prisoners at Michigan's Jackson State Prison appealed to the Sixth Circuit Court of Appeals the decision of the U.S. District Court for the Eastern District of Michigan's ruling that state prison officials were not acting unreasonably when they prohibited the Detroit Metropolitan Community Church from conducting congregate worship services at the prison. The Detroit Metropolitan Community Church is a member of the Universal Fellowship of Metropolitan Community Churches, which ministers to the spiritual needs of homosexuals in and out of prisons. Prison authorities denied church officials and inmate members the privilege of conducting worship services because they linked homosexuality with prison violence. Officials argued that the presence of worship services by the church would result in the increased identification of homosexuals in prison who otherwise would not be identified as homosexual. For prison officials, the increased identification of homosexuals could lead to an increased victimization of the homosexual prisoners identified as such by predators, and an increase in other prison violence among others who would compete with each other to form relationships with the homosexual prisoners. As an alternative to worship services, prison authorities allowed the church to conduct individual counseling sessions with prisoners and made religious ministry sessions available. The prisoners and church officials maintained that they had the First Amendment's free exercise of religion right to conduct worship services because other churches were allowed to conduct services with inmates of other faiths. The prisoners also argued they were denied the Fourteenth Amendment's equal protection of the law.

Issue

Whether state prison officials can deny inmates their First and Fourteenth Amendment affiliation with the Universal Fellowship of Metropolitan Community Churches, which ministers to the special religious needs of homosexuals, while allowing other churches to hold worship service.

Court of Appeals Holding

The Court of Appeals affirmed the decision of the District Court after finding that prison officials expressed a reasonable security concern in preventing prison violence by denying the Universal Fellowship of Metropolitan Community Churches the privilege of...