Broderick Risper v. Latota Hughes, et al.

Summary

The United States District Court for the Central District of Illinois ruled on defendants’ motion for summary judgment in a prisoner’s claims under the Religious Land Use and Institutionalized Persons Act and the First Amendment. The court denied summary judgment on the RLUIPA claim, finding a genuine issue as to whether prison officials substantially burdened the plaintiff’s religious exercise by denying or conditioning possession of religious items. The court granted summary judgment on the First Amendment claim, dismissed the unidentified John Doe defendant without prejudice, and referred the matter for a settlement conference.

Holdings

1. Defendants were not entitled to summary judgment on Risper's RLUIPA claim because the record permitted a reasonable inference that officials substantially burdened his religious exercise and Defendants failed to show that denying the requested accommodation was the least restrictive means of furthering a compelling governmental interest.
2. The First Amendment Free Exercise claim was granted against Plaintiff because it was moot in light of the court's determination that RLUIPA provided greater protection for the same conduct.
3. The John Doe defendant was dismissed without prejudice because Plaintiff failed to identify that defendant within the deadlines in the court's Scheduling Order.
4. Qualified immunity did not bar Plaintiff's RLUIPA claim because only injunctive relief was available and qualified immunity does not protect defendants from actions for injunctive relief.

Questions Presented

1. Whether Defendants were entitled to summary judgment on Risper's RLUIPA claim based on the denial and destruction of his religious medallion, chain, and cross.
2. Whether Risper's First Amendment Free Exercise claim should be dismissed or resolved in light of the greater protection afforded by RLUIPA.
3. Whether the unidentified John Doe defendant should be dismissed because Risper failed to identify that defendant within the court-ordered deadline.
4. Whether qualified immunity barred Risper's RLUIPA claim.

Disposition

other