Wiggins v. Sargent

In Wiggins v. Sargent (8th Cir. 1985) 753 F.2d 663, the question before the court of appeals was whether the Arkansas Department of Correction violated several inmates' First Amendment rights by prohibiting their receipt of religious literature and correspondence with faith-based leaders. The district court held the inmates' beliefs were not religious in nature. The court of appeals found the district court may have erred in its conclusion to the contrary and remanded the matter for further consideration. ( Id. at pp. 666-667.) The court of appeals held: "The district court was correct in noting that only sincerely held beliefs which are 'rooted in religion' are protected by the free exercise clause. First amendment religious protection is not extended to 'so-called religions which tend to mock established institutions and are obviously shams and absurdities and whose members are patently devoid of religious sincerity.' . . .From a review of the limited evidence presented at the hearing, we believe that the district court may have erred in its conclusion that the inmates' beliefs are purely secular. Followers of the churches involved here base their beliefs directly on literal interpretations of fundamentalist Christian theology. They believe that the Bible teaches that race mixing is a sin. However 'unpalatable' such ideas are, it is not a court's prerogative to determine the validity of such beliefs. The belief system here has its own orders of worship and Articles of Faith, not to mention the fact that it has outside-the-prison organization and followers. It has its own religious dogma, hierarchy, and mandated lifestyle. It also appears that the inmates' religion may be comprehensive and that it may address fundamental and ultimate questions. Cf. Africa v. Com. of Pa., supra, 662 F.2d 1025 . . . ." ( Wiggins, 753 F.2d at p. 666.)