The Volokh Conspiracy

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Religion and the Law

Lucifer Dodges a Lawsuit


From Watts v. Lucifer, decided yesterday by Judge Sam Crow (D. Kan.):

Petitioner James B. Watts, who is proceeding pro se and in forma pauperis, is a pretrial detainee incarcerated at the Butler County Jail facing state criminal charges…. Petitioner … [filed various motions, including a motion] titled "Motion to Get Page 1 of My Petition for Habeas Corpus with Case No. of GOD Almighty's Number(s) and, Not of Lucifer's (Satan's, The Devil's)…" Therein, Petitioner explained his belief that certain numbers are "of God Almighty's Number(s)," while others are "of Lucifer's" numbers.

The case number administratively assigned to this matter when Petitioner filed it is 22-3109-SAC; the number 2 is one of the numbers Petitioner believes is Lucifer's. In his motion, Petitioner asserted that using "[a]ny…numbers that do not add up to GOD Almighty's are [sic] against [his] Religion and/or Faith," and he asked the Court to alter the case number to include only "GOD Almighty's Number(s) and Not…Lucifer's." …

Petitioner … asserts that he "will not get any justice under this case" number because the case number "is for Evil [and] Wicked people and their justice." He advises the Court that if it declines to comply with his requests to … grant Petitioner's motions, it should dismiss this case without prejudice so that Petitioner may proceed in another, identical habeas action he has initiated in this Court….

[T]he Court notes that Petitioner's newer habeas action has also been assigned a case number that begins with 2. See Watts v. Lucifer, Case No. 22-3195-JWL-JPO. This is because both of Petitioner's current habeas actions were filed in the year 2022. The first two digits of every case number reflect the year in which the case was filed. Thus, any cases Petitioner files on or before January 1, 2030 will be administratively assigned a case number that begins with a 2. Therefore, dismissing this matter so that Petitioner may proceed in his more recently filed habeas action will not resolve Petitioner's numerical complaint….

[T]he Court … does not take lightly Petitioner's religious objections to his case number. However, Petitioner does not identify any legal authority that supports his demand that the Court change the administratively assigned case number to comport with Petitioner's religious beliefs. In fact, the Court's independent research has revealed only legal authority that supports the denial of Petitioner's request.

For example, in the context of a religious objection to the assignment of a social security number, the United States Supreme Court held that the Free Exercise Clause does not require "that the Government join in [an individual's] chosen religious practices by refraining from using a number to identify [his or her] daughter." See Bowen v. Roy (1986). The Court explained: "The Free Exercise Clause affords an individual protection from certain forms of government compulsion; it does not afford an individual a right to dictate the conduct of the Government's internal procedures." Similarly, the Court has discovered no legal authority that gives Petitioner the right to demand that his administratively assigned case number be altered to comport with Petitioner's religious beliefs….

The Bowen v. Roy analysis strikes me as quite correct here. See also Mayo v. Satan and His Staff (W.D. Pa. 1971).