Michael Brandon Whetsell v. Lieutenant Williams, Kitchen Supervisor

Summary

The United States District Court for the District of South Carolina denied Defendant Lieutenant Williams’s motion for summary judgment in a prisoner civil-rights action concerning the alleged denial of kosher meals. The Court held that genuine disputes of material fact remained regarding whether Plaintiff’s religious practice was substantially burdened, whether Defendant was entitled to qualified immunity, and whether Plaintiff exhausted administrative remedies. The Court adopted the Magistrate Judge’s Report and Recommendation and dismissed the official-capacity claim for monetary damages under the Eleventh Amendment.

Holdings

1. Eleventh Amendment immunity bars Plaintiff's § 1983 claim against Defendant in her official capacity for monetary damages, while Defendant sued in her individual capacity is a person amenable to suit under § 1983.
2. Defendant was not entitled to summary judgment because the evidence created a genuine dispute of material fact as to whether Plaintiff was actually provided kosher meals and whether the failure substantially burdened his sincere religious practice.
3. Defendant was not entitled to summary judgment on qualified immunity because the genuine dispute of material fact concerning the alleged failure to provide kosher meals prevented resolution of the defense at that stage.
4. Defendant was not entitled to summary judgment on exhaustion because she failed to establish the requirements of the detention center's grievance procedure or explain why Plaintiff's submitted grievance did not comply with those requirements.
5. The court denied Defendant's motion for summary judgment because genuine disputes of material fact remained concerning the alleged denial of kosher meals and the resulting burden on Plaintiff's religious practice.

Questions Presented

1. Whether Defendant was entitled to summary judgment on Plaintiff's First Amendment Free Exercise claim because Plaintiff's kosher diet had been approved.
2. Whether the evidence created a genuine dispute over whether Plaintiff was actually provided kosher meals and whether the alleged failure substantially burdened his religious practice.
3. Whether Defendant was entitled to qualified immunity at the summary-judgment stage.
4. Whether Plaintiff failed to exhaust administrative remedies under the detention center's grievance policy.
5. Whether Eleventh Amendment immunity barred Plaintiff's official-capacity claim for monetary damages under 42 U.S.C. § 1983.

Disposition

other