Summary
This Eighth Circuit Court of Appeals opinion reverses the district court’s denial of a preliminary injunction sought by a Christian volunteer who was barred from teaching a religiously-themed prison program called "The Quest for Authentic Manhood" at a Minnesota correctional facility. The appellate court held that the Minnesota Department of Corrections’ decision to terminate the program was not viewpoint-neutral and likely violated the appellant’s First Amendment rights to free speech and free exercise of religion. The case remands for entry of an order reinstating the program pending full adjudication on the merits.
Topics
Practice areas
Questions Presented
- Whether the MDOC's termination of the Quest program violates the First Amendment free speech and free exercise rights and the Establishment Clause.
- Whether the Turner test applies or strict scrutiny should govern the constitutional analysis.
Holdings
- The district court erred; the termination was not neutral and therefore fails the Turner test, making Schmitt likely to succeed on the merits, requiring reversal of the denial of the preliminary injunction.
Key quotations
“The government must abstain from regulating speech when the specific motivating ideology or the opinion or perspective of the speaker is the rationale for the restriction.” (*4)
“When the government wishes to state an opinion, . . . to formulate policies, it naturally chooses what to say and what not to say.” (*4)
Factual background
Anthony Schmitt, a Christian volunteer, taught the "Quest for Authentic Manhood" program at the Minnesota Correctional Facility. The program presented a biblical perspective on masculinity. In 2023 the MDOC terminated the program, stating it conflicted with the department's diversity, equity, and inclusion values. Schmitt sued alleging violations of his First Amendment free speech, free exercise, and Establishment Clause rights.
Procedural history
Schmitt filed suit after the Minnesota Department of Corrections terminated his "Quest for Authentic Manhood" program. The district court denied his motion for a preliminary injunction. Schmitt appealed to the Eighth Circuit.
Remand instructions
Entry of an order reinstating the Quest program at MCF pending a full adjudication of the case on the merits.