RALEIGH, N.C. — A federal judge appointed to the bench by then-President Ronald Reagan has ruled that the North Carolina Department of Public Safety and the Lanesboro Correctional Institution were in error in declining to recognize an inmate’s religion as humanism, and prohibiting him from forming a humanist study group.
“[D]efendants have not demonstrated a secular purpose for denying humanism recognition as a religious group or for the decision to prohibit humanist inmates from organizing group meetings,” wrote U.S. District Judge Terrence Boyle on Thursday.
“Defendants’ refusal to recognize humanism as a faith group and to accommodate humanist meetings violates the Establishment and Equal Protection Clauses,” he said.
As previously reported, the American Humanist Association (AHA) had filed suit last July on behalf of Kwame Teague, who has been behind bars since 1996 and wishes to meet with other humanists who share his views. His records indicate that he is Islamic, but he has requested that officials change his religious affiliation to note that he is rather a secular humanist.
However, the North Carolina Department of Public Safety does not include humanism or atheism in its list of recognized religions, as it does not view adherents as being a part of a religious group.
Reasons for rejecting Teague’s request have included notations that humanism “appears to be a philosophy of life, a free way of thinking” as opposed to a form of religious worship, that it does not draw from a single source for direction, but is rather based on “individual belief” on how one can live for the “greater good” of humanity, and that humanists “do not believe in a deity, but drew from a Christian way of thinking on how to treat their fellow man.”
Teague disagrees that these factors should disqualify humanists from being recognized. He says that while atheism and humanism are not theistic, they are still “equivalent to a religion.”
“Whereas atheism is a religious view that essentially addresses only the specific issue of the existence of a deity, the humanism affirmed by Teague is a broader worldview that includes, in addition to a non-theistic view on the question of deities, an affirmative naturalistic outlook; an acceptance of reason, rational analysis, logic, and empiricism as the primary means of attaining truth; an affirmative recognition of ethical duties; and a strong commitment to human rights,” AHA’s complaint read.
It also argued that humanism has a similar structure to religion because it utilizes clergy members known as “celebrants” to officiate ceremonies, and observes special days, such as Darwin Day.
On Thursday, Judge Boyle concluded that the Department violated the Establishment Clause to the U.S. Constitution in declining to recognize humanism as a religion, since “DPS has recognized other faith groups, such as American Indian, Wicca, Hinduism, Asatru, Rastafarianism, and Buddhism, which also lack a centralized head or the
formal structure or hierarchy of other religions.”
“The record … reflects that DPS prison officials expressed skepticism and bias toward humanism because it did not have a ‘religious tone’ and its members ‘did not believe in a deity,'” he wrote. “Defendants, additionally, have not set forth any evidence to support space, resource, or security concerns applicable to humanist inmates, which do not apply equally to Christian, Muslim, Buddhist, or Wiccan inmates.”
“Rather, on record before the court, DPS’s arbitrary decision to recognize some faith groups, and not humanism, fostered an excessive government entanglement with religion,” Boyle stated. “For these reasons, the court concludes that DPS violated both the second and third factors of the Lemon test and, therefore, the Establishment Clause.”
He ruled that since other non-theistic groups deemed to be religious have been allowed to meet, humanist inmates have wrongfully been “treated differently.”
Boyle consequently ordered the Department to “recognize humanism as a faith group and as an assignment option for OPUS and all other prison records, and permit Teague and other humanist inmates to meet in a humanist study group on the same terms defendants authorize for inmates of recognized faith groups.”
The Department is currently reviewing the ruling and has not yet made a decision as to whether an appeal will be filed.
Psalm 100:3 says, “Know ye that the Lord, He is God. It is He that hath made us, and not we ourselves.”