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    Ulbricht V Federal Bureau of Prisons (5/5/2021)

    Uploaded by

    Ethan Biando
    This document is an original complaint filed by Ross Ulbricht against the Federal Bureau of Prisons. The complaint alleges that the BOP is violating Ulbricht's rights under the Religious Freedom Restoration Act by refusing to allow him to use the prison email system (TRULINCS) to communicate with his father, who lives in a remote part of Costa Rica and only has access to email. Ulbricht believes his Christian faith requires him to honor his father, and that the inability to email him substantially burdens his religious exercise. The complaint requests an injunction requiring the BOP to allow Ulbricht to use TRULINCS to email his father, as well as costs and attorney's fees.

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    © All Rights Reserved
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    Ulbricht V Federal Bureau of Prisons (5/5/2021)

    Uploaded by

    Ethan Biando
    2K views4 pages
    This document is an original complaint filed by Ross Ulbricht against the Federal Bureau of Prisons. The complaint alleges that the BOP is violating Ulbricht's rights under the Religious Freedom Restoration Act by refusing to allow him to use the prison email system (TRULINCS) to communicate with his father, who lives in a remote part of Costa Rica and only has access to email. Ulbricht believes his Christian faith requires him to honor his father, and that the inability to email him substantially burdens his religious exercise. The complaint requests an injunction requiring the BOP to allow Ulbricht to use TRULINCS to email his father, as well as costs and attorney's fees.

    Original Description:

    Ross Ulbricht's federal lawsuit against the FBOP concerning religion

    Original Title

    Ulbricht v Federal Bureau of Prisons (5/5/2021)

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    © © All Rights Reserved

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    This document is an original complaint filed by Ross Ulbricht against the Federal Bureau of Prisons. The complaint alleges that the BOP is violating Ulbricht's rights under the Religious Freedom Restoration Act by refusing to allow him to use the prison email system (TRULINCS) to communicate with his father, who lives in a remote part of Costa Rica and only has access to email. Ulbricht believes his Christian faith requires him to honor his father, and that the inability to email him substantially burdens his religious exercise. The complaint requests an injunction requiring the BOP to allow Ulbricht to use TRULINCS to email his father, as well as costs and attorney's fees.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    2K views4 pages

    Ulbricht V Federal Bureau of Prisons (5/5/2021)

    Uploaded by

    Ethan Biando
    This document is an original complaint filed by Ross Ulbricht against the Federal Bureau of Prisons. The complaint alleges that the BOP is violating Ulbricht's rights under the Religious Freedom Restoration Act by refusing to allow him to use the prison email system (TRULINCS) to communicate with his father, who lives in a remote part of Costa Rica and only has access to email. Ulbricht believes his Christian faith requires him to honor his father, and that the inability to email him substantially burdens his religious exercise. The complaint requests an injunction requiring the BOP to allow Ulbricht to use TRULINCS to email his father, as well as costs and attorney's fees.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    You are on page 1of 4

    Case 4:21-cv-00195-DCB-PSOT Document 1 Filed 05/05/21 Page 1 of 4

    1 Brandon Sample
    2 Brandon Sample PLC
    PO BOX 250
    3
    Rutland, VT 05702
    4 Tel: 802-444-4357
    5 Fax: 802-779-9590
    E-mail: brandon@brandonsample.com
    6

    7
    IN THE UNITED STATES DISTRICT COURT
    8
    FOR THE DISTRICT OF ARIZONA
    9 TUCSON DIVISION
    10

    11
    Ross Ulbricht, Case No.:
    12
    Plaintiff,
    13
    ORIGINAL COMPLAINT
    14 vs.
    15
    Federal Bureau of Prisons,
    16
    Defendant.
    17

    18

    19
    I. Introduction

    20 1. This suit is brought pursuant to the Religious Freedom


    21
    Restoration Act (“RFRA”), which prohibits the federal government from
    22

    23 substantially burdening a person’s sincere exercise of religion unless


    24
    that burden is supported by a compelling governmental interest and
    25

    26 applied through the least restrictive means. 42 U.S.C. § 2000bb, et seq.


    27
    2. Plaintiff Ross Ulbricht (“Ulbricht”) is a practicing Christian.
    28
    ORIGINAL COMPLAINT - 1
    Case 4:21-cv-00195-DCB-PSOT Document 1 Filed 05/05/21 Page 2 of 4

    1 Ulbricht alleges that the Federal Bureau of Prisons’ (“BOP”) is


    2
    substantially burdening his exercise of religion because BOP refuses—
    3

    4 in violation of RFRA—to permit him to use TRULINCS to exchange e-


    5
    mail communication with his father.
    6

    7 II. Parties
    8
    3. Ross Ulbricht is an inmate incarcerated in federal prison. His
    9

    10 federal register number is # 18870-111. His mailing address is FCI


    11
    Tucson, P.O. BOX 24550, Tucson, AZ 85734.
    12

    13 4. Defendant Federal Bureau of Prisons is a federal agency. Its


    14
    mailing address is 320 First St. N.W., Washington, DC 20534.
    15

    16 III. Jurisdiction
    17
    5. This Court has jurisdiction over Ulbricht’s RFRA claims under 28
    18

    19
    U.S.C. § 1331.

    20 IV. Statement of Facts


    21
    6. Ulbricht is a practicing Christian who is incarcerated in federal
    22

    23 prison. Ulbricht sincerely believes, consistent with his Christian faith,


    24
    that he is obliged to honor his father and mother.
    25

    26 7. This command derives from Exodus 20:12 which states, “Honor


    27
    your father and your mother, so that you may live long in the land the
    28
    ORIGINAL COMPLAINT - 2
    Case 4:21-cv-00195-DCB-PSOT Document 1 Filed 05/05/21 Page 3 of 4

    1 LORD your God is giving you.”


    2
    8. Ulbricht’s father, Kirk Ulbricht (“Kirk”), lives in Matapalo, Costa
    3

    4 Rica.
    5
    9. Matapalo is a remote area of Costa Rica.
    6

    7 10. Ulbricht’s father does not have access to phone or mail because of
    8
    Matapolo’s remoteness.
    9

    10 11. However, Ulbricht’s father does have access to satellite internet.


    11
    12. As such, the only way for Ulbricht to communicate with his father
    12

    13 is via e-mail.
    14
    13. Ulbricht loves his father very much. Communicating with his
    15

    16 father is very important to him.


    17
    14. Ulbricht sincerely believes that his inability to communicate with
    18

    19
    his father is inconsistent with Exodus 20:12.

    20
    15. Without approval from the BOP to use TRULINCS, the only way
    21
    Ulbricht can e-mail with his father is by using another inmate’s
    22

    23 TRULINCS account. Ulbricht, to be clear, does not do this. Doing so


    24
    would violate the BOP’s inmate discipline program and subject Ulbricht
    25

    26 to loss of good conduct time and other sanctions.


    27
    16. Consequently, Ulbricht is in a “catch 22” of sorts—do not
    28
    ORIGINAL COMPLAINT - 3
    Case 4:21-cv-00195-DCB-PSOT Document 1 Filed 05/05/21 Page 4 of 4

    1 communicate with his father in violation of his sincerely held religious


    2
    beliefs or communicate with his father in violation of the BOP’s rules,
    3

    4 exposing Ulbricht to penalties and sanctions.


    5
    Count One
    6

    7 17. Paragraphs 1-16 are hereby reincorporated as fully set forth


    8
    herein.
    9

    10 18. BOP’s refusal to allow Ulbricht to use TRULINCS to e-mail with


    11
    his father violates RFRA.
    12

    13 Relief Requested
    14
    19. Ulbricht requests the following injunctive relief:
    15

    16 (a) An order requiring the BOP to allow Ulbricht to use TRULINCS

    17
    so Ulbricht may e-mail with his father.
    18

    19
    20. Ulbricht requests his costs and attorney’s fees.

    20 21. Finally, Ulbricht urges the Court to grant him any and all other
    21
    relief the Court deems just and fit.
    22

    23 Respectfully submitted,
    24
    /s/Brandon Sample
    25
    Brandon Sample
    26

    27

    28
    ORIGINAL COMPLAINT - 4

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