8th Circuit rules against Indian inmate in religious rights case

The Mash-ka-wisen Treatment Center in Sawyer, Minnesota. Photo from Findthebest.com

An Indian inmate who wanted to participate in a culturally-sensitive chemical dependency program lost a ruling before the 8th Circuit Court of Appeals today.

Wesley Eugene Brooks is a member of the Shakopee Mdewakanton Sioux Community of Minnesota. He objected to being placed in a 12-step program that he said forced him to “profess beliefs that are inconsistent with his faith," the decision stated.

Brooks sought a transfer to a different facility in order to participate in a more culturally-appropriate program at the Mash-ka-wisen Treatment Center, 191 miles away. His request was denied so he filed a lawsuit in federal court, claiming that his religious rights and civil rights were violated.

The 8th Circuit, however, said Brooks failed to properly state a claim. He wasn't specific enough about his beliefs and he didn't detail how the 12-step program conflicted with them, the court said.

"To be clear, we are challenging neither the sincerity of Brooks’s beliefs nor his assertion that his beliefs are religious in nature," the decision stated. "We are saying only that, based on his complaint, we cannot discern what beliefs he has or what faith he professes. Because the defendants were not put on notice of his claims, judgment properly was granted in their favor."

At the same time, the 8th Circuit was sympathetic to Brooks -- who is due to be released at the end of March -- due to the "complex" and "confusing" nature of the grievance process in the Minnesota corrections system. The court indicated that he was free to amend his complaint or file a new one.

"The confusing nature of the grievance procedures gives us pause," the court stated. "We also wonder whether inmates and prison administrators alike might benefit from more transparent and easy-to-follow procedures—particularly when failure to exhaust the remedies available in the prison’s policies can be fatal to an inmate’s legal cause of action."

The Mash-ka-wisen Treatment Center is located in Sawyer, on the Fond du Lac Reservation. It has provided chemical dependency treatment services to Native Americans for more than 30 years.

Turtle Talk has posted documents from the case, Brooks v. Roy. Oral arguments can be found on the Indianz.Com SoundCloud.

8th Circuit Decision:
Brooks v. Roy (January 27, 2015)

Oral Arguments Indianz.Com SoundCloud:

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