Cruz v. Beto Supreme Court Case (1972): Summary & Case Brief

Instructor: Kenneth Poortvliet
The First Amendment protects the right to worship as one sees fit. In this lesson, we will see how the Supreme Court dealt with a prisoner's right to worship freely.

That's My Right!

Do you have the same rights in prison as you do outside prison? Most would think not. You are locked up, told where to go, what to do and when to do it. However, what if the prison let members of other faiths go to meetings and pray at certain times, but not you? Does this seem fair? This is the issue the Supreme Court decided in Cruz v. Beto (1972).

Facts of the Case

Fred Cruz was a Mexican-American man born in San Antonio, Texas. He got involved in drugs at an early age and committed crimes to support his habit. At age 21, police arrested him for ''robbery by assault,'' and the judge sentenced him to 50 years in prison. While in prison, he became a Buddhist, and he claimed that prison officials denied him his ability to worship.

He claimed that Christians, Catholics, and Jews were given the time to meet to pray and engage in their faith, were given Bibles, and were able to hold Sunday classes and other religious services. Also, prisoners got good merit points as a reward for attending those meetings which went toward them possible getting out earlier.

When he attempted to share his faith with other inmates, Cruz was thrown in solitary confinement. He filed a lawsuit in federal district court against the prison to gain the right to be given the same opportunities to worship as those of other faiths.

The district court denied his claim without a hearing, stating that when it came to areas of prison activities, it should be left ''to the sound discretion of prison administration.'' The court of appeals affirmed the lower court's decision, and Cruz appealed to the U.S. Supreme Court.

Historical Background

Before the early 1900's, the Supreme Court adopted the hands off policy when it came to state prisoners. The idea was that the federal government had no business interfering in state prison matters, even denying prisoners protection under the Eighth Amendment's cruel and unusual punishment clause. In the 1872 case Ruffin v. Commonwealth the Supreme Court said, ''A convicted felon has, as a consequence of his crime, not only forfeited his liberty, but all of his personal rights except those which the law in its humanity accords him. He is for the time being a slave of the state.''

However, in Robinson v. California (1962), the Supreme Court reversed this doctrine by holding that the Eighth Amendment did apply to state prisoners. Then in Cooper v. Pate (1964), the Supreme Court held that state prisoners had standing to sue for their constitutional rights, and also held that when it comes to religion, the state prisons must treat all prisoners equally. The Court didn't explain what that meant, but it provided a basis for religious rights in prison cases.

Issue and Decision

The Supreme Court was asked whether a Texas prison violated Cruz's religious rights by not affording him the same opportunities to worship as prisoners of other faiths. The Court held that Texas had indeed violated Cruz's religious rights.

In the Supreme Court's opinion, the Court first addressed the district court's denial of Cruz's right to a hearing on his claim. The Court said, ''We are not unmindful that prison officials must be accorded latitude in the administration of prison affairs.... But persons in prison, like other individuals, have the right to petition the Government for redress of grievances.''

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