Summary
This memorandum from the U.S. District Court for the Middle District of Pennsylvania addresses a pro se inmate's motions to compel discovery of his presentence investigation report and psychological assessments. The court denied the motions, finding that the requested documents were not relevant to the plaintiff's religious freedom claims under RLUIPA and RFRA, and that their disclosure would violate confidentiality protections necessary for the integrity of correctional evaluations. The ruling reiterates prior decisions limiting access to such sensitive materials while outlining the standard of review for discovery disputes under Federal Rules of Civil Procedure 26 and 37.
Topics
Practice areas
Questions Presented
- Whether the plaintiff's presentence investigative report and psychological assessments are discoverable under Fed. R. Civ. P. 37 and 26(b)(1).
- Whether the confidentiality interests in the documents outweigh the plaintiff's relevance interests.
Holdings
- The motions to compel discovery are denied because the documents are not relevant to the plaintiff's RLUIPA claim and are protected by confidentiality interests.
Key quotations
““Inmates clearly retain protections afforded by the First Amendment... including its directive that no law shall prohibit the free exercise of religion.””
““The statute forbids the government from imposing ‘a substantial burden’ on a prisoner's religious exercise unless the government demonstrates that imposition of the burden … is in furtherance of a compelling governmental interest; and … is the least restrictive means of furthering that compelling governmental interest.””
Factual background
Inmate Jonathan Robins, confined at the Rockview State Correctional Institution, alleges that a sex‑offender treatment program required him to admit guilt for conduct that occurred with his minor wife, violating his free‑exercise rights under RLUIPA and the Pennsylvania Constitution. He seeks the program's presentence investigative report and psychological assessments.
Procedural history
Plaintiff filed a §1983 action; the district court dismissed as frivolous. The Third Circuit vacated the dismissal on the free‑exercise claim and remanded. Plaintiff filed amended complaints, which were stricken. The defendants moved to dismiss; the court dismissed RFRA claims and allowed RLUIPA claims to proceed. Plaintiff now seeks discovery of his presentence report and psychological assessments; the court denied the motions.