Richard Thomas Gardipee v. St. Johns County

Summary

The United States District Court for the Middle District of Florida dismissed Richard Thomas Gardipee’s pro se civil-rights action against St. Johns County without prejudice. The court held that the compensatory damages Gardipee sought were unavailable against the county for his alleged RLUIPA violation and directed the Clerk to enter judgment and close the case.

Holdings

1. The plaintiff could not obtain compensatory damages against the county for the alleged RLUIPA violation; the only relief he sought was therefore unavailable.
2. The complaint's request for $14 million in compensatory damages could not be liberally construed as a request for nominal damages.
3. The action was dismissed without prejudice, with leave for Gardipee to refile claims under 42 U.S.C. § 1983 supported by sufficient factual allegations against a proper defendant.

Questions Presented

1. Whether the complaint stated a claim subject to relief under the PLRA screening provisions.
2. Whether a RLUIPA claim against St. Johns County could proceed when the plaintiff sought only compensatory damages.
3. Whether the pro se complaint's request for compensatory damages could be liberally construed as a request for nominal damages.

Disposition

dismissed