Murder conviction upheld for satanist who claimed his religious freedom was violated during trial
A federal appeals court panel has upheld the conviction of a Texas man in the death of a 15-year-old girl, rejecting his claim that prosecutors violated his religious beliefs by introducing evidence of his satanic beliefs at trial.
Irving Alvin Davis was convicted of sexual assault and murder in the 2001 death of Melissa Medina. Davis brutally beat, strangled, sexually assaulted and mutilated the victim, including cutting off her fingertips and attempting to sever her hand to destroy DNA evidence.
Following his capital murder conviction in 2002, Texas’ highest criminal court, the Court of Criminal Appeals (CCA), granted Davis a retrial. During his re-sentencing, prosecutors provided evidence of Davis’ satanic beliefs, including personal writing and drawings, to argue that he posed a future threat to society.
Prosecutors also brought in an expert on satanism who described the role of human sacrifice in satanic practices.
According to court documents, Davis’ drawings contained “violent and sexually explicit content,” including depictions of a “crying woman who is bound, gagged and nearly naked” and “a woman with a slashed throat.”
Davis claimed that his constitutional rights were violated by prosecutors introducing his satanic beliefs, the CCA denied his claim, and he was again sentenced to death.
Davis was later granted a certificate of appealability by the 5th U.S. Circuit Court of Appeals, which upheld Davis’ conviction in an opinion filed June 25 by Judge Jerry Smith.
The 5th Circuit held that the CCA’s rejection of the First Amendment claim was neither contrary to nor an unreasonable application of clearly established Supreme Court law in Dawson v. Delaware and other cases.
The court affirmed that the evidence was relevant to assessing Davis’ future threat to society, since it included his own materials and references to violent interpretations of satanism. Smith found the state court’s findings reasonable and upheld the conviction.
“The CCA noted that the state had introduced prison records showing that Davis had identified himself as a Satanist since 2005 and had owned various Satanic religious publications that discussed rituals of destruction and human sacrifice,” the judge wrote. “The CCA concluded, therefore, that it was ‘within the zone of reasonable disagreement for the trial court to decide that the evidence of satanism was relevant to the issue of future dangerousness.’”
In 2010, Davis made a similar appeal, arguing that prosecutors wrongfully informed jurors about his satanic beliefs. A federal appellate court later upheld the ruling.
The rise of groups, including The Satanic Temple (TST), has seen an increased appeal to religious freedom by organizations that worship Satan.
In April, a Colorado school district provided a tailored religious accommodation to a high school student who identified as a satanist, exempting her from the school's digital hall pass system specifically for restroom access during class.
In a letter to the district, TST legal counsel Matt Kezhaya argued that the school’s bathroom monitoring system burdened the student’s religious exercise by placing school authority over her bodily autonomy, the group said in a public statement on its website.
The letter also referenced the U.S. Supreme Court’s 2025 ruling in Mahmoud v. Taylor, which addressed parents’ rights to opt children out of instruction conflicting with their religious beliefs.
“By its very nature, the system requires [the student] to subordinate her bodily needs to institutional surveillance and control,” Kezhaya wrote in the letter.
