James Damion Mack v. Mr. Hackett

Summary

The document is a Memorandum Opinion and Recommendation by a United States Magistrate Judge in a prisoner civil-rights action under 42 U.S.C. § 1983. It recommends granting Defendant Mr. Hackett’s motion for summary judgment on the plaintiff’s First Amendment Free Exercise and Fourteenth Amendment Equal Protection claims. The recommendation concludes that the plaintiff failed to establish a constitutional violation and that qualified immunity applies.

Holdings

1. Mack’s allegation that he missed one Jumu’ah service while undergoing a brief processing period did not establish a substantial burden on his ability to practice his religion; a single or isolated incident does not substantially burden an inmate’s religious exercise.
2. Even assuming the processor policy substantially burdened Mack’s religious exercise, the policy was reasonably related to legitimate and neutral penological interests and therefore did not violate the First Amendment.
3. Mack failed to establish an Equal Protection violation because he did not show that Hackett treated similarly situated prisoners differently or that any unequal treatment resulted from intentional or purposeful religious discrimination.
4. Hackett was entitled to qualified immunity because the record failed to establish that he violated Mack’s First or Fourteenth Amendment rights.

Questions Presented

1. Whether excluding Mack from one group Jumu’ah service while he was an unclassified prison processor substantially burdened his First Amendment right to freely exercise his religion.
2. Whether the prison’s processor policy violated the First Amendment under the Turner v. Safley reasonableness factors.
3. Whether Mack established that Hackett intentionally treated him differently from similarly situated prisoners because of religion, in violation of the Fourteenth Amendment Equal Protection Clause.
4. Whether Hackett was entitled to qualified immunity on Mack’s § 1983 claims.

Disposition

other