Cruz v. Beto, 405 U.S. 319 (1972), was a United States Supreme Court case in which the court upheld a Free Exercise claim based on the allegations that the state of Texas had discriminated against a Buddhist prisoner by "denying him a reasonable opportunity to pursue his Buddhist faith comparable to that offered other prisoners adhering to conventional religious precepts."
Background
Fred Arispe Cruz, a Mexican-American born in San Antonio, Texas in 1939, was often in trouble with the police in his teenage years and became addicted to heroin. In 1960, at 21, Cruz was arrested and convicted of “robbery by assault”. He was sentenced to 50 years in a state prison in 1961.
Cruz denied taking part in the robberies. Wanting to appeal his conviction but unable to afford a lawyer, Cruz began to read all of the law books that he could find in the prison library. Despite only having an 8th-grade education, Cruz filed his first pro se appeal to the robbery charge in 1962. Fed up with the harsh field labor, brutal corporal punishments, and arbitrary disciplinary hearings experienced by prisoners, Cruz used his newfound knowledge to write a lawsuit against the prison system.
Because of his “legal activities” Cruz was classified as an agitator and transferred to the “Ellis Unit” in 1963. At the Ellis Unit, Cruz was pushed to drop his lawsuit by enduring many hours of solitary confinement. In 1967 Cruz wrote to Reverend Hogen Fujimoto, minister in the Shin Buddhist Churches of America (BCA) to request information on Buddhism. Cruz shared the information he received with other inmates which landed him back in solitary, which at the time meant a bread and water diet with a small meal served every third day.
Despite the abusive conditions, Cruz succeeded in filing his own lawsuit as well as those of other inmates. One of the suits Cruz assisted with is that of a Muslim at the facility who argued that his civil rights were being violated. Warden McAdams punished two inmates for the incident and kept Muslim prisoners at work in the fields six days a week instead of the five days assigned to other inmates. Within days a riot broke out in the Muslim cell block.
This 1968 riot was the first at Ellis Unit and helped build solidarity among prisoners and gain the attention of outsiders. One of these outsiders was Frances Jalet (later Frances Jalet-Cruz, as Cruz and Jalet were married after his prison release), an attorney whom Cruz had contacted in 1967 after reading about her in a newspaper. Jalet, along with attorney William Bennett Turner, would assist Cruz in his watershed case, Cruz v. Beto.
Case
Cruz, a Buddhist, complained that he was not allowed to use the prison chapel, that he was prohibited from writing to his religious advisor, and that he was placed in solitary confinement for sharing his religious material with other prisoners. Cruz filed the lawsuit using his own toilet paper ration. The Federal District Court initially denied relief without a hearing or findings, holding the complaint to be in an area that should be left "to the sound discretion of prison administration."
An amended complaint argued that: "While prisoners who are members of other religious sects are allowed to use the prison chapel, Cruz is not. He shared his Buddhist religious material with other prisoners and, according to the allegations, in retaliation was placed in solitary confinement on a diet of bread and water for two weeks, without access to newspapers, magazines, or other sources of news. He also alleged that he was prohibited from corresponding with his religious advisor in the Buddhist sect."
and contrasted that with the fact that the prison: "...encourages inmates to participate in other religious programs, providing at state expense chaplains of the Catholic, Jewish, and Protestant faiths; providing also at state expense copies of the Jewish and Christian Bibles, and conducting weekly Sunday school classes and religious services. According to the allegations, points of good merit are given to prisoners as a reward for attending orthodox religious services, those points enhancing a prisoner's eligibility for desirable job assignments and early parole consideration"
so: "...plaintiff and the members of the class he represents are being subjected to an arbitrary and unreasonable exclusion without any lawful justification which invidiously discriminates against them in violation of their constitutional right of religious freedom and denies them equal protection of the laws."