Summary
This Seventh Circuit opinion addresses an inmate's claims against the Wisconsin Department of Corrections regarding its policy prohibiting inmate-led religious programming. The court affirmed summary judgment in favor of the department on the inmate's RLUIPA claim, finding the policy was the least restrictive means of furthering compelling security interests. However, the court vacated and remanded the state-law breach-of-contract claim because the district court improperly relinquished supplemental jurisdiction over only the remedy portion rather than the entire claim.
Topics
Practice areas
Questions Presented
- Whether WDOC's prohibition on inmate-led religious programming and use of alternative programming violated RLUIPA because the policy was not the least restrictive means of furthering the compelling governmental interest in prison safety and security.
- Whether a district court may retain jurisdiction and enter judgment on liability for a state-law claim while relinquishing supplemental jurisdiction over the requested remedy under 28 U.S.C. § 1367(c).
Holdings
- WDOC's policy prohibiting inmate-led religious programming and providing alternative programming when outside or staff religious leaders are unavailable was the least restrictive means of furthering the compelling governmental interests in prison safety and security; summary judgment for WDOC on West's RLUIPA claim was therefore proper.
- A district court may not enter judgment on liability for a state-law claim while relinquishing supplemental jurisdiction over the remedy portion of that same claim; under 28 U.S.C. § 1367(c), the court must decide whether to retain or relinquish jurisdiction over the entire claim.
Key quotations
“Because a plaintiff’s prayer for relief does not comprise a “claim” under any definition, the district court abused its discretion by entering judgment as to liability, but renouncing supplemental jurisdiction over the remedy.” (126 F.4th at 582)
“In short, the district court correctly concluded on this record that WDOC’s Policy is the least restrictive means of achieving its goal of maintaining prison safety and security.” (126 F.4th at 579)
Factual background
West is a Muslim inmate at Green Bay Correctional Institution who contends that Jumu'ah congregational prayer and Talim study groups are required or important components of his religious practice. WDOC policy generally prohibited inmates from leading religious gatherings and required services to be led or facilitated by chaplains, staff, or qualified community volunteers, while permitting alternative programming when such leaders were unavailable. After the parties settled West's prior RLUIPA lawsuit, WDOC canceled six Talim study groups in September 2016, leading West to bring this action alleging RLUIPA and breach-of-settlement-agreement claims.
Procedural history
West previously sued WDOC under RLUIPA concerning its prohibition on inmate-led religious programming; the parties resolved that lawsuit through a September 2016 settlement agreement. West filed this second action in 2017, alleging that WDOC violated RLUIPA and breached the settlement agreement by prohibiting inmate-led programming, using alternatives, and canceling six Talim study groups. The district court granted WDOC summary judgment on the RLUIPA claim, granted West partial summary judgment on contract liability, and dismissed only the injunctive-relief portion of the contract claim without prejudice after relinquishing supplemental jurisdiction. The Seventh Circuit affirmed the RLUIPA judgment, vacated the partial contract judgment, and remanded.
Remand instructions
The district court must determine, in its discretion, whether to retain or relinquish supplemental jurisdiction over the entire state-law breach-of-contract claim. The partial judgment on liability must be vacated; the judgment in WDOC's favor on the RLUIPA claim remains affirmed.