Summary
The United States Court of Appeals for the Tenth Circuit reviewed Ahmad Ajaj’s claims concerning religious accommodations in federal prison under the Religious Freedom Restoration Act. The court reversed dismissal of his group-prayer claim as moot, concluding that the district court misunderstood the evidence regarding the frequency of group prayer available to him. It also held that RFRA permits qualified immunity to be asserted in individual-capacity damages actions, but left the merits of that defense for the district court to decide on remand.
Topics
Practice areas
Questions Presented
- Whether Ajaj's RFRA group-prayer claim became moot when he was transferred from ADX to a program that provided some opportunities for communal prayer.
- Whether RFRA authorizes monetary damages against federal officials sued in their individual capacities.
- Whether qualified immunity may be invoked by federal officials sued for damages in their individual capacities under RFRA.
Holdings
- The group-prayer claim was not properly dismissed as moot because the district court's ruling rested on the clearly erroneous factual finding that Ajaj could pray with others five times daily at Terre Haute.
- RFRA authorizes monetary damages claims against federal officials sued in their individual capacities.
- Qualified immunity may be invoked by officials sued for damages in their individual capacities under RFRA.
Key quotations
“Although missing one or two daily prayers might be considered a permissible burden on Mr. Ajaj’s religious beliefs, that goes to the merits of his RFRA claim, not its justiciability.” (14)
“We conclude that qualified immunity can be invoked by officials sued for damages in their individual capacities under RFRA. We reverse the district court’s dismissal of Mr. Ajaj’s individual-capacity claims and remand for the court to determine whether the relevant defendants are entitled to immunity.” (23)
Factual background
Ahmad Ajaj, a practicing Muslim and federal inmate, alleged that BOP facilities substantially burdened his religious exercise by restricting Ramadan and Sunnah fasting accommodations, halal food, access to an imam, and communal prayer. After he was transferred from ADX Florence to the Life Connections Program at USP Terre Haute, the district court concluded that his group-prayer claim was moot because the program allowed communal prayer. The record showed, however, that Ajaj could not necessarily participate in all five daily group prayers, and his access depended on facility schedules and cell-release limits. Ajaj also sought damages from individual BOP officials under RFRA, but the district court dismissed those claims on the ground that RFRA did not authorize individual-capacity damages.
Procedural history
Ajaj sued the Federal Bureau of Prisons for injunctive relief and BOP officials for damages based on alleged burdens on his Muslim religious practices. The district court dismissed the Ramadan medication claim as moot, dismissed the group-prayer claim as moot after Ajaj's transfer to a different facility, and dismissed the RFRA damages claims against individual-capacity defendants because it concluded that RFRA did not authorize such damages. The Tenth Circuit reversed both challenged rulings and remanded for further proceedings, including consideration of qualified immunity in the first instance.
Remand instructions
The district court must reconsider the group-prayer claim without relying on the clearly erroneous finding that Ajaj could pray with others five times daily. It must also determine in the first instance whether the individual defendants are entitled to qualified immunity on any of the RFRA damages claims. The district court may consider changed circumstances on remand. Ajaj's motion to supplement the appellate record was denied as moot.