Gabriel Stecker v. Bill Anderson, et al.

Summary

The United States District Court for the Eastern District of Missouri grants Gabriel Stecker leave to proceed without prepaying fees and allows RLUIPA claims to proceed against several SORTS officials in their official capacities, including unidentified Doe defendants. The court dismisses without prejudice claims against certain defendants, all RLUIPA claims against individuals in their individual capacities, and the plaintiff’s First Amendment claims under 42 U.S.C. § 1983.

Holdings

1. The complaint plausibly alleged that the confiscation of Stecker's Halloween Forever oracle deck and booklet substantially burdened his religious exercise and that the identified care-team members and SORTS directors could be responsible for the challenged conduct. Process therefore issued on the RLUIPA claims against those defendants in their official capacities.
2. RLUIPA does not authorize claims against state officials in their individual capacities. Stecker's individual-capacity RLUIPA claims were dismissed without prejudice.
3. The action could proceed against the Doe defendants because Stecker identified them by job title and description and discovery would likely permit their identities to be learned.
4. The claims against Killion, Borrajo, and Chamberlin were dismissed without prejudice because the complaint did not connect them directly to the alleged confiscation or a policy that caused the confiscation.
5. The First Amendment claims were dismissed without prejudice because the complaint did not identify which defendants allegedly violated the First Amendment or the capacity in which they were sued.

Questions Presented

1. Whether the complaint plausibly alleged that SORTS officials substantially burdened Stecker's religious exercise in violation of RLUIPA.
2. Whether RLUIPA claims could proceed against state officials in their individual capacities.
3. Whether the complaint stated plausible RLUIPA claims against the identified care-team members, SORTS directors, Doe defendants, and supervisory or policy-related defendants.
4. Whether the complaint stated a First Amendment claim under 42 U.S.C. § 1983 when it did not identify which defendants violated the First Amendment or the capacity in which they were sued.

Disposition

other