A Satanist has won at least a symbolic victory in a prisoner rights case as officials at a Montana jail agreed to pay him $100 for denying his requests for a copy of The Satanic Bible.

Jason Indreland

The minimal settlement resolved Jason Indreland's only remaining claim arising from his incarceration at the Yellowstone County Detention Facility between March 2007 and July 2008. He is now serving five years in a state prison, with two years suspended, for felony drug possession.

During the litigation of the case, the jail chaplain noted that the themes of The Satanic Bible “include the promotion of vengeance, self-gratification, the killing of individuals who Satanists believe “deserve” to be killed, symbolic destruction of victims, living according to individual desires without regard for conscience or consequences, and rebellion against law.”

Those themes, Chaplain Sam Kinser argued in a brief, “are all directly contrary to the desired goals of incarceration which is [sic] the rehabilitation of the individual and preparing him to be a productive member of society.”

But courts around the country have split over whether corrections officials have a “legitimate penological interest” in not allowing inmates access to The Satanic Bible. And a June 14 court filing shows that Kinser and Yellowstone County each agreed to pay Indreland $50 rather than contest the matter further.

In a pro se complaint filed in November 2008, Indreland said he had been “a practicing Satanist for the past 10 years” but was unable to freely exercise his First Amendment rights while he resided at the Yellowstone County jail. Officials denied his requests for items including The Satanic Bible and a Satanic medallion.

A U.S. district judge summarily dismissed most of the case in March, adopting a magistrate's finding that officials had a legitimate interest in prohibiting an inmate from having a medallion with a chain that is thick enough to be used to strangle someone.

As far as The Satanic Bible, county officials argued that it “advocates violence, manipulation, disregard for authority and revenge.” But U.S. Magistrate Judge Carolyn S. Ostby said they had cited “no evidence for this proposition, nor is there anything in the record to indicate that this was the reason Indreland’s request was denied.”

“The Court understands that this justification has been upheld by a number of other courts finding there is a legitimate penological interest in not allowing inmates access to the Satantic [sic] Bible,” she continued, but “there is also authority for finding no such legitimate penological interest.”

In McCorkle v. Johnson, 881 F.2d 993 (1989), the 11th U.S. Circuit Court of Appeals said Alabama prison officials did not violate the free exercise rights of an inmate by denying him access to The Satanic Bible. “The teachings of The Satanic Bible ... present a significant threat to security and order within the prison,” it warned.

But as an Illinois judge has noted, the plaintiff in that case “held an extreme view on Satanism that called for human sacrifice, drinking of blood, wrist slashing and consuming the flesh of humans while they were still alive.” Semla v. Snyder.

By Matthew Heller
7/5/10