Eighth Circuit Rejects DEI-Based Policies in Landmark First Amendment Ruling on Prison Education
In a pivotal decision shaking up debates over diversity policies and free speech, the U.S. Court of Appeals for the Eighth Circuit has ruled against using DEI rationales to censor religious content in prisons. This reversal highlights growing tensions between equity initiatives and constitutional rights.
Case Background: A Clash Between Faith and Prison Policies
Anthony Schmitt, a Christian volunteer, sought to teach a Bible-based course on manhood at Minnesota state prisons. The program, titled “Quest for Authentic Manhood,” drew from Christian teachings on gender roles and personal development.
The Minnesota Department of Corrections (MDOC) rejected the curriculum. Officials cited conflicts with the department’s diversity, equity, and inclusion (DEI) values, arguing the course promoted outdated stereotypes about masculinity.
Schmitt filed suit in federal court, claiming viewpoint discrimination under the First Amendment. He requested a preliminary injunction to allow the class while the case proceeded.
The U.S. District Court for the District of Minnesota denied the injunction in August 2024. It applied the deferential standard from Turner v. Safley, which gives prisons leeway in regulating inmate activities for security and rehabilitation.
Schmitt appealed to the Eighth Circuit, arguing the denial violated his free speech and religious exercise rights.
The Eighth Circuit’s Decision: Reversing the Denial
On August 14, 2025, the Eighth Circuit reversed the district court’s ruling in a 2-1 opinion. The court directed the lower court to grant the preliminary injunction, allowing Schmitt to teach the course pending trial.
Judge Lavenski R. Smith, writing for the majority and joined by Judge Jonathan A. Kobes, held that MDOC’s rejection constituted impermissible viewpoint discrimination. The court rejected the department’s DEI-based rationale, stating prisons cannot suppress religious perspectives simply because they clash with equity policies.
The majority emphasized that while prisons deserve deference under Turner, this standard does not extend to outright censorship of volunteer-led educational content based on ideological grounds.
Dissenting View
Judge Jane Kelly dissented, arguing the district court properly deferred to prison officials’ expertise. She contended the DEI policy served legitimate penological interests, such as promoting inclusivity among inmates.
Expert Opinions and Public Reactions
Legal experts hailed the ruling as a win for religious freedom. The Upper Midwest Law Center (UMLC), representing Schmitt alongside True North Legal, called it a “joint victory” against government overreach. UMLC stated the decision affirms that “viewpoint discrimination has no place in our prisons or anywhere else.”
Emily McAdam, writing for Law.com, noted the case’s broader implications: It questions the weight courts should give to DEI rationales in public policy, potentially influencing similar disputes beyond prisons.
Public reactions have been mixed, with conservative groups praising the protection of Christian viewpoints, while DEI advocates worry it could undermine efforts to foster inclusive environments in correctional facilities.
Impact on U.S. Readers: Politics, Rights, and Prison Reform
This ruling resonates amid national debates over DEI in government and education. Politically, it bolsters arguments against mandatory equity training, especially under recent executive orders scrutinizing federal DEI programs.
For everyday Americans, it underscores First Amendment protections in public institutions. In prisons, where rehabilitation affects community safety, the decision could expand access to faith-based programs, potentially improving inmate outcomes and reducing recidivism.
On a broader scale, it may influence workplace and school policies, encouraging challenges to DEI initiatives seen as restricting speech. This could shift how states like Minnesota balance equity goals with constitutional freedoms.
Conclusion: A Step Toward Balanced Rights
The Eighth Circuit’s reversal in Schmitt v. Rebertus marks a significant rebuke to DEI-driven censorship in prisons. By prioritizing First Amendment rights, the court sets a precedent that could reshape policy rationales nationwide.
Looking ahead, the full trial may clarify DEI’s role in government decisions. Meanwhile, this decision empowers religious volunteers and highlights the need for neutral application of prison rules. As debates evolve, it reminds us that equity must not come at the expense of free expression.
Eighth Circuit ruling, DEI policies, First Amendment rights, prison curriculum case, religious freedom in prisons, Minnesota Department of Corrections, viewpoint discrimination, Schmitt v. Rebertus, preliminary injunction reversal, U.S. court decisions