Ramirez v. Collier

John Henry Ramirez was sentenced to death for the 2004 murder of Pablo Castro. His execution was scheduled in Texas, but the prison refused to allow his pastor to lay hands on him and pray audibly during the execution, citing security concerns. Ramirez sued under the Religious Land Use and Institutionalized Persons Act (RLUIPA), arguing the restriction substantially burdened his religious exercise. Lower courts sided with the state, but the U.S. Supreme Court reversed in an 8-1 decision on March 24, 2022. The Court held that Ramirez was likely to succeed on the merits, finding that Texas failed to show its blanket ban was the least restrictive means of furthering its security interest. The case was remanded, effectively requiring the prison to accommodate the religious ritual unless it could demonstrate a more narrowly tailored restriction.

The U.S. Supreme Court granted a stay of execution and reversed the lower courts, holding that the inmate was likely to succeed on his RLUIPA claim. The case was remanded for further proceedings, and the state was required to allow the requested religious accommodation unless a more narrowly tailored security measure could be justified. Ramirez was subsequently executed on October 5, 2022, with his pastor permitted to touch him and pray audibly.

Whether a prison’s refusal to permit a death row inmate’s pastor to lay hands on him and pray aloud during execution violates the inmate’s rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA), and whether the state’s security justification satisfies the “least restrictive means” test.

The ruling strengthened religious liberty protections for death row inmates, clarifying that blanket security rationales are insufficient under RLUIPA and that prisons must show a compelling interest satisfied through the least restrictive means. It set a significant precedent for religious accommodation in execution protocols nationwide, prompting many states to review and revise their policies to allow spiritual advisors to engage in audible prayer and physical touch during executions.