Smith v. Halstead
- Cathy Seibel
- 7:24-cv-06855
- U.S. District Court · Southern District of New York
- 3
In Smith v. Halstead, Judge Seibel ordered more evidence on Smith’s religious-practice injunction request without deciding whether the rules violate federal law.
Donnie P. Smith and the County of Orange; the County was required to provide a further response concerning the rules affecting Smith’s religious practices.
What happened
In Smith v. Halstead, Donnie P. Smith sought an order limiting rules about religious practices, including limits on necklaces and a ban on pictures on cell walls. The court had previously denied his request except as to religious practice and asked the County of Orange to respond.
The court said Smith had not yet explained his religious beliefs, how the rules burdened them, or what events violated the Religious Land Use and Institutionalized Persons Act or the First Amendment. It ordered him to submit an affidavit or declaration, and optionally a legal memorandum, by August 14, 2025.
Judge Cathy Seibel also ordered the County to respond within 30 days after receiving Smith’s submission, including affidavits or declarations and a legal memorandum. The order did not decide whether Smith was entitled to an injunction; it said the County’s explanation was too vague and needed to address safety or security interests and whether the rules were appropriately limited.
The detailed version
- Smith v. Halstead · No. 7:24-cv-06855
- Cathy Seibel
- July 15, 2025
Background
Donnie P. Smith applied for a temporary restraining order and preliminary injunction concerning his religious practices. The application implicated the Religious Land Use and Institutionalized Persons Act (RLUIPA), which can restrict government burdens on religious exercise in institutions, and the First Amendment’s protection for religious exercise.
In an earlier order, the court denied the application except insofar as it concerned religious practice and requested a response from the County of Orange. The County’s July 14, 2025 response described general rules limiting the number of necklaces and prohibiting pictures on cell walls.
Court’s Analysis
The court explained that, under RLUIPA, the government must show that a substantial burden on religious exercise advances a compelling governmental interest and uses the least restrictive means of advancing that interest. For a First Amendment claim, restrictions affecting prisoners’ constitutional rights must be reasonably related to legitimate institutional interests. The court also identified factors concerning the connection between the rule and the governmental objective, alternative ways to exercise the right, the effects of accommodation, and less burdensome alternatives.
The court found that Smith had not provided enough detail about what his religious beliefs require, why the necklace and picture rules burden or substantially burden his religious exercise, or what happened to infringe his rights. It also found that the County’s explanation—apart from vague references such as “safety and security”—did not identify the compelling interest served by the rules, explain why they were the least restrictive means, or address the factors relevant to the First Amendment analysis.
Order and Effect
The court ordered Smith to provide an affidavit or declaration on those issues by August 14, 2025. He may also submit a memorandum of law. The County must respond within 30 days after receiving Smith’s submission, with supporting affidavits or declarations and a memorandum of law.
Judge Cathy Seibel did not decide the religious-practice portion of the injunction request in this order. The order stated that, if an inmate’s religion required a picture on the wall, a jail could not forbid it solely because of a general no-pictures rule; the jail would need to provide more information connecting the rule to security, safety, or a similar interest and address the other applicable factors.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.