Gutierrez v. Saenz

Ruben Gutierrez, a Texas death row inmate convicted of the 1998 murder of 85-year-old Escolastica Harrison, sued Texas prison officials after they refused to allow his spiritual advisor to touch him and pray audibly during his execution. The case reached the U.S. Supreme Court, which issued a decision on June 26, 2025. The Court held that Texas likely violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) by denying the requested religious accommodation without demonstrating a compelling governmental interest. The ruling vacated the lower court's decision and remanded the case, allowing Gutierrez's religious liberty claim to proceed.

The U.S. Supreme Court ruled in favor of Gutierrez, finding that Texas's restrictions likely violate RLUIPA. The Court vacated the lower court ruling and remanded for further proceedings consistent with its opinion.

Whether Texas's execution protocol prohibiting a spiritual advisor from touching and vocalizing prayers during lethal injection violates the Religious Land Use and Institutionalized Persons Act and the free exercise of religion.

The decision reinforced religious liberty protections for death row inmates nationwide, requiring states to justify restrictions on spiritual advisors during executions and influencing future execution protocol litigation.