Andrew J. Hawkins v. Chad Youker

Summary

The court granted Andrew J. Hawkins leave to proceed in forma pauperis and assessed the full civil filing fee under the Prison Litigation Reform Act. On screening, the court allowed his First Amendment, RLUIPA, and Tennessee statutory claims concerning the alleged removal of religious materials to proceed against Captain Chad Youker, while dismissing claims under the Federal Tort Claims Act, Spending Clause, and Commerce Clause. The matter was referred to a magistrate judge for further proceedings.

Holdings

1. The complaint plausibly stated a First Amendment free-exercise claim because it alleged a sincerely held religious belief and facts from which a factfinder could infer that the jail's alleged ban on physical Bibles and other religious materials impermissibly impinged religious exercise.
2. The complaint plausibly stated an RLUIPA claim based on the alleged substantial burden imposed by the jail's prohibition on physical Bibles and Alcoholics Anonymous materials.
3. The RLUIPA claim could proceed against Captain Youker in his official capacity, but any individual-capacity RLUIPA claim for money damages was dismissed.
4. The complaint plausibly stated a claim under Tennessee Code Annotated § 41-21-211 because it alleged that official jail policies denied inmates access to a Bible during nonworking hours.
5. The Federal Tort Claims Act claims were dismissed for failure to state a claim because Hawkins sued a county employee rather than the United States.
6. Any independent claims under the Spending Clause or Commerce Clause were dismissed because the complaint did not explain what claims Hawkins intended to assert under those provisions.

Questions Presented

1. Whether the complaint plausibly stated First Amendment free-exercise and RLUIPA claims based on an alleged jail policy prohibiting possession of physical Bibles and Alcoholics Anonymous materials.
2. Whether the complaint stated a Tennessee-law claim under Tennessee Code Annotated § 41-21-211 based on the alleged denial of access to a Bible.
3. Whether the RLUIPA claim could proceed against Captain Youker in his individual capacity for money damages.
4. Whether the complaint stated claims under the Federal Tort Claims Act, the Spending Clause, or the Commerce Clause.

Disposition

other