Cruz v. Beto, 405 U.S. 319 (1972), was a United States Supreme Court case in which the court upheld a Free Exercise claim based on the allegations that the state of Texas had discriminated against a Buddhist prisoner by "denying him a reasonable opportunity to pursue his Buddhist faith comparable to that offered other prisoners adhering to conventional religious precepts."
Fred Arispe Cruz, a Mexican-American born in San Antonio, Texas in 1939, was often in trouble with the police in his teenage years and became addicted to heroin.
Wanting to appeal his conviction but unable to afford a lawyer, Cruz began to read all of the law books that he could find in the prison library.
In 1967 Cruz wrote to Reverend Hogen Fujimoto, minister in the Shin Buddhist Churches of America (BCA) to request information on Buddhism.
Cruz shared the information he received with other inmates which landed him back in solitary, which at the time meant a bread and water diet with a small meal served every third day.
[2] The Federal District Court initially denied relief without a hearing or findings, holding the complaint to be in an area that should be left "to the sound discretion of prison administration."
There cannot possibly be any constitutional or legal requirement that the government provides materials for every religion and sect practiced in this diverse country.
Absent a complaint alleging facts showing that the difference in treatment between the petitioner and his fellow Buddhists and practitioners of denominations with more numerous adherents could not reasonably be justified under any rational hypothesis, I would leave the matter in the hands of the prison officials.It has been assumed that the dismissal by the trial court must be treated as proper only if the standard of Conley v. Gibson, 355 U.S. 41 (1957), would permit the grant of a motion under Fed.
I would not require the district court to inflexibly apply this general principle to the complaint of every inmate, who is in many respects in a different litigating posture than persons who are unconfined.