Ephraim v. Angelone.

U.S. District Court

RELIGIOUS DIET

Ephraim v. Angelone, 313 F.Supp.2d 569 (E.D.Va. 2003). A state prison inmate who was a Charismatic Christian brought a suit claiming that a prison violated his constitutional rights by failing to use his new religiously-inspired name and to honor his dietary requests. The district court entered judgment in favor of the prison. The court held that the inmate's equal protection rights were not violated when he was a denied a vegetarian diet his religion allegedly required, because there were no other members of his religion in his prison that were treated differently, nor was there any showing of intentional discrimination. The court found that the strict scrutiny test set forth in the Religious Land Use and Institutionalized Persons Act (RLUIPA) was not required because there was no showing that the prison was receiving federal funding, or that the burden imposed on the inmate affected interstate commerce. The court held that the prison did not violate the free exercise of religion rights of the inmate by continuing to use the name under which he was committed when preparing money orders and on official documents. The court noted that prison computers were programmed with the commitment name and the prison's unwillingness to change programs to allow for the name substitution furthered a legitimate interest in holding down costs. The court also held that the inmate's right to free exercise of his Charismatic Christian religion was not violated when the prison declined to completely accommodate his dietary request for raw vegetables, fresh fruit, nuts, honey, whole wheat bread, cheese and grains; it was sufficient for the prison to offer the inmate a vegetable option in lieu of meat main courses, in the interest of controlling costs. (Lunenburg Correctional Center, Virginia)