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New York Inmates Say Planned Solar Eclipse Lockdown Violates Their Constitutional Rights

— April 2, 2024

The Woodbourne Correctional inmates–hailing from disparate religious backgrounds–all claim that a planned state-wide lockdown will deprive them of a constitutionally-protected spiritual experience that they will likely never again have an opportunity to witness.

A half-dozen inmates in a New York prison have filed a lawsuit against the state Department of Corrections, claiming that a planned lockdown would prevent them from watching a once-in-a-lifetime solar eclipse.

According to ABC News, a total or near-total solar eclipse has not occurred in New York since 1925—and will not likely recur in the region until 2079.

Although some inmates had purportedly received permission to view the eclipse, the state Department of Corrections and Community Supervision later reversed course. In a March 11 memo, DCCS Acting Commissioner Daniel Martuscello III said that the agency will take a “proactive approach to ensure the safety of staff, visitors, and the incarcerated population, and to ensure the integrity of our facilities during this event.”

The department’s “proactive approach” involves locking down all of its facilities statewide, including those that are not in the path of the eclipse, and prohibiting visitation during the eclipse’s expected peak.

But the plaintiffs—all men incarcerated at Woodbourne Correctional Facility—now argue that the eclipse “is a significant religious event for people of many different faith backgrounds,” and that depriving them of the opportunity to witness it is an abridgement of their constitutional rights.

Image via Rennett Stowe/Flickr/Wikimedia Commons. (CCA-BY-2.0)

ABC News notes that the six prisoners claim varied religious backgrounds—with one of the men being Muslim, another Baptist, a Seventh-Day Adventist, an atheist, and two practitioners of Santeria. Despite their differences, each has purportedly “expressed a sincerely held religious belief that April’s solar eclipse is a religious event that they must witness and reflect on to observe their faiths.”

One of the inmates named in the complaint, Jeremy Zielinski, said that he had earlier requested—and was given—permission to view the eclipse. Although Zielinski is an atheist, he said that the eclipse that provides an opportunity to celebrate “triumph and reason.” However, once Woodbourne’s lockdown was announced, corrections officials revoked his permission.

“Mr. Zielinski firmly believes that observing the solar eclipse with people of different faiths is crucial to practicing his own faith because it is a central aspect of atheism to celebrate common humanity and bring people together to encourage people to find common ground,” the lawsuit alleges.

“To be able to put aside our differences and just enjoy something together is really, really important,” Zielinski told Hell Gate NYC. “There’s not that many opportunities to do it, especially in [prison]. When you have an opportunity like that, it’s a shame to waste it.”

David Haigh, the Seventh-Day Adventist, provided a somewhat more secular-sounding reason to Hell Gate.

“It will be 20 years before another opportunity like this exists,” Haigh said, referring to a 2044 solar eclipse that will be visible only in three states—all far from New York. “I don’t believe that, just because I am incarcerated, that I should be denied this opportunity.”

“[…] Even for a non-religious person,” Haigh said, “this eclipse could hold some sort of special meaning.”

Thomas Malley, a spokesperson for the state corrections department, said that—while the agency does not comment on pending litigation—it takes all requests for religious accommodations seriously, and all those related to the eclipse are currently under review.


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