Randy Haight v. LaDonna Thompson
763 F.3d 554 (2014)
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Rule of Law:
Under the Religious Land Use and Institutionalized Persons Act (RLUIPA), prison officials may not deny inmates' requests for religious accommodations based on vague, after-the-fact security concerns, as this may impose a substantial burden on religious exercise requiring the government to satisfy strict scrutiny. However, RLUIPA's provision for 'appropriate relief' does not permit inmates to recover money damages from prison officials sued in their individual capacities.
Facts:
- Robert Foley, Roger Epperson, and Vincent Stopher, three death-row inmates in a maximum-security Kentucky prison, practiced a Native American faith.
- The inmates requested access to a sweat lodge for religious ceremonies, offering to pay for it themselves.
- The warden denied the sweat lodge request in January 2010, reasoning that no other Kentucky prison had one and granting the request would set a precedent.
- The inmates also made repeated requests for traditional foods, including buffalo meat and corn pemmican, for their annual powwow ceremony, and offered to pay for the items.
- The prison denied the requests for buffalo meat and corn pemmican, though it did provide 'special traditional bread' for the ceremony.
- Separately, inmates Randy Haight and Gregory Wilson sought access to visiting clergy.
- Prior to June 2010, the prison allowed clergy to visit under a 'special visit' exception, but then changed its policy to require clergy to be on an inmate's single, approved visitation list.
- While the inmates' lawsuit was pending, the state again changed its visitation policy to allow clergy to appear on multiple inmates' lists, satisfying the inmates' request for future access.
Procedural Posture:
- Five death-row inmates filed a lawsuit in the U.S. District Court for the Western District of Kentucky against prison officials, alleging violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA).
- The inmates sought both injunctive relief to allow their religious practices and money damages.
- The district court granted summary judgment in favor of the defendant prison officials on all claims.
- The district court held that the denials of the sweat lodge and ceremonial foods did not violate RLUIPA, and that the Act does not permit money damages claims against officials.
- The five inmates, as appellants, appealed the district court's grant of summary judgment to the U.S. Court of Appeals for the Sixth Circuit.
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Issue:
Under the Religious Land Use and Institutionalized Persons Act (RLUIPA), is a prison's denial of an inmate's religious accommodation request, based on generalized and post-hoc security concerns, sufficient to satisfy the government's burden to show it used the least restrictive means to further a compelling interest?
Opinions:
Majority - Sutton, J.
No. A prison's denial of religious accommodation requests based on generalized, post-hoc security concerns is insufficient to satisfy the government's burden under RLUIPA's strict scrutiny standard. First, regarding the sweat lodge, the prison's initial justifications—that the request was novel and would set a precedent—are not compelling governmental interests under RLUIPA. The security concerns raised later in litigation affidavits are suspect as post-hoc rationalizations and are too abstract to satisfy the government's burden as a matter of law. The prison failed to show it considered less restrictive alternatives or investigated how numerous other prisons accommodate such requests. Second, regarding ceremonial foods, completely barring access to sincerely requested items like buffalo meat and corn pemmican 'effectively bars' the religious practice and imposes a 'substantial burden.' The government cannot determine which practices are 'central' to a faith. A triable issue of fact exists for both accommodation claims. Finally, RLUIPA's provision for 'appropriate relief' does not permit money damages against officials in their individual capacity. The Spending Clause requires Congress to be unmistakably clear when imposing conditions on federal funds, and the phrase 'appropriate relief' is too ambiguous to clearly authorize monetary damages.
Concurring - Cole, C.J.
Yes, I agree that the inmates cannot recover money damages, but the majority's reasoning is flawed. The majority's reliance on Sossamon v. Texas is misplaced because that case was decided on sovereign immunity grounds, which does not apply to suits against officials in their individual capacities. The correct rationale is that under the Spending Clause, as clarified in Arlington Central, Congress must provide 'clear notice' of the remedies available for non-compliance with the conditions attached to federal funds. RLUIPA’s ambiguous phrase 'appropriate relief' does not provide clear notice to states that their individual officials could be held liable for money damages. The court should not address the Commerce Clause argument as it was not raised below and doing so would violate the doctrine of constitutional avoidance.
Analysis:
This decision reinforces the robust protections of RLUIPA, making it more difficult for prison officials to deny religious accommodations using vague or after-the-fact justifications. It clarifies that the government's burden under strict scrutiny requires specific, contemporaneous evidence tailored to the particular inmate and request, rather than generalized security fears. The ruling places a higher evidentiary burden on prisons at the summary judgment stage, likely leading to more thorough administrative reviews of RLUIPA requests. By joining every other circuit to consider the issue, the court also solidified the national consensus that RLUIPA's remedies are limited to injunctive relief and do not include money damages against individual officers, channeling inmate litigation toward compelling future compliance rather than seeking past compensation.
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