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Denial of Satanic Bible Results in $100 Settlement

Yellowstone County, Montana agreed to pay $100 to settle First Amendment and RLUIPA claims brought by a prisoner who was denied a Satanic Bible.

While incarcerated at the Yellowstone County Detention Facility, Jason Indreland, a practicing Satanist, requested that he be provided with a copy of the Satanic Bible. Under the facility’s rules, “religious materials, such as a bible, [could] be requested by submitting an inmate request form to the facility Chaplain.”

The Chaplain, however, denied Indreland’s request. Indreland filed a grievance but his grievance was denied, too. According to the grievance response, “Per our Facility Chaplain – Satanism is not encouraged in our facility. You will not be given ... items pertaining to Satanism. This is final per Administration.”

Indreland filed suit in federal court alleging the denial of his request for a Satanic Bible violated the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA).

The defendants moved for summary judgment on the basis that Indreland was denied a Satanic Bible due to security concerns.

The district court, however, refused to accept this post-hoc rationalization, noting there was not “anything in the record to indicate that this was the reason Indreland’s request was denied.”

After supplemental briefing regarding the denial of the Satanic Bible, the parties agreed to settle the case for $100 in September 2010. See: Indreland v. Bell, U.S.D.C. (D. Mont.), Case No. 1:08-cv-00047-RFC-CSO.

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Related legal case

Indreland v. Bell