Summary
This Report and Recommendation from a U.S. Magistrate Judge in the District of Nevada addresses an inmate’s motion for a temporary restraining order and preliminary injunction seeking expanded chapel access at the Lovelock Correctional Center. Applying the legal standards for mandatory preliminary injunctions and the Religious Land Use and Institutionalized Persons Act (RLUIPA), the Court evaluates whether the current chapel schedule substantially burdens the plaintiff’s religious exercise. Finding that the prison administration demonstrated a compelling governmental interest and used the least restrictive means to accommodate all faith groups, the Magistrate Judge concludes the plaintiff has not shown a likelihood of success on the merits or irreparable harm. Consequently, the Court recommends denying the injunctive relief while granting leave to file excess pages.
Topics
Practice areas
Questions Presented
- Whether the request for chapel access on August 15, 2025 is moot
- Whether Riggs satisfied the RLUIPA and PLRA requirements for a mandatory preliminary injunction
- Whether Riggs demonstrated likelihood of success on the merits and irreparable harm
Holdings
- The request is moot because the date has passed, so the motion is denied as moot.
- The motions for temporary restraining order and preliminary injunction are denied because Riggs failed to show a likelihood of success on the merits and failed to demonstrate irreparable harm.
Key quotations
“The purpose of a preliminary injunction or temporary restraining order is to preserve the status quo if the balance of equities so heavily favors the moving party that justice requires the court to intervene to secure the positions until the merits of the action are ultimately determined.” (at 18)
“A preliminary injunction is an “extraordinary and drastic remedy” that is “never awarded as of right.”” (at 22)
Factual background
Daniel Riggs is an inmate at the Nevada Department of Corrections Lovelock Correctional Center. He alleges that the prison’s chapel schedule substantially burdens his Catholic religious practice and that the prison has not provided adequate accommodation for Catholic and Latter‑day Saint worship.
Procedural history
Inmate Daniel Riggs filed a motion for a temporary restraining order and a preliminary injunction alleging violations of the Free Exercise and Establishment Clauses, the Equal Protection Clause, and RLUIPA. The United States Magistrate Judge issued a report and recommendation denying the relief and granting a motion to file excess pages.