Brown v. Peters, et al.

Summary

The court screened Michael Brown’s amended § 1983 complaint under 28 U.S.C. § 1915A. It allowed First Amendment Free Exercise and Fourteenth Amendment Equal Protection claims to proceed against several prison dietary and administrative officials, and allowed RLUIPA and Illinois RFRA claims for official-capacity injunctive relief against two defendants. The court dismissed certain defendants and claims without prejudice for failure to state a claim and directed service and related case-management procedures.

Holdings

1. Brown plausibly stated a Free Exercise Clause claim against Chaplain Thousand, Assistant Warden Arnett, Dietary Managers Peters and Willis, and Dietary Supervisors Wilcoxen, Harminson, Reneau, and Blanco based on the alleged denial of Passover meals without yeast or leaven.
2. Brown plausibly stated an Equal Protection Clause claim against Thousand, Arnett, Peters, Willis, Wilcoxen, Harminson, Reneau, and Blanco by alleging that Jewish inmates received commercially prepared Passover meals without yeast or leaven while Hebrew Israelite inmates received meals containing those substances.
3. Brown plausibly stated official-capacity claims under RLUIPA and IRFRA against Chaplain Thousand and Assistant Warden Arnett, the officials identified as responsible for implementing injunctive relief.
4. Boughan, Hubbard, and Smithers were dismissed without prejudice because grievance mishandling alone does not establish personal liability and the complaint alleged no facts showing Smithers's personal involvement in a constitutional deprivation.

Questions Presented

1. Whether Brown plausibly alleged that prison officials substantially burdened his religious exercise by denying him meals without yeast or leaven during Passover.
2. Whether Brown plausibly alleged an Equal Protection Clause violation by alleging that Jewish inmates received compliant Passover meals while Hebrew Israelite inmates did not.
3. Whether Brown stated official-capacity claims for injunctive or declaratory relief under RLUIPA and IRFRA.
4. Whether Brown stated claims against grievance officials and a dietary supervisor based on grievance handling or the absence of allegations showing personal involvement.

Disposition

other