Jackson v. Nixon

Drug Court

Jackson v. Nixon

Case Year: 
2014
State of Origin: 
Missouri

A Missouri prisoner, alleged that being required to attend and complete a non-secular substance abuse program in order to be eligible for early parole violated the Establishment Clause.  The Eighth Circuit ruled that the district court erred in dismissing the claim on the ground that the prisoner voluntarily withdrew from the program and that such a withdraw was fatal to his claims as it could not be determined, at this stage of the proceedings, whether his withdrawal was voluntary or the result of state-sponsored coercion; to evaluate a prisoner's claim of coercion, the court would conduct a three-step inquiry: has the state acted, does the action amount to coercion, and is the object of the coercion secular or religious; the first and third prongs were present here, and based on the allegations of the complaint, the court found that the plaintiff pled facts sufficient to state a claim that a parole stipulation requiring him to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment.