James Dalton #1170 v. Chad Youker

Summary

The United States District Court for the Middle District of Tennessee grants James Dalton leave to proceed in forma pauperis and leave to amend his complaint. The court permits Dalton’s First Amendment free-exercise and retaliation claims, RLUIPA claim, and Tennessee-law claim concerning the alleged removal and restricted access to Bibles at the Williamson County Jail to proceed, while dismissing any individual-capacity RLUIPA claim for damages. The court holds Dalton’s emergency motion for injunctive relief in abeyance and directs service of process on Captain Chad Youker.

Holdings

1. The amended complaint states claims sufficiently colorable to proceed under the First Amendment, RLUIPA, and Tennessee law, subject to later dismissal under the PLRA or a motion to dismiss.
2. Allegations that jail officials prohibited possession of physical Bibles and restricted or obstructed access to religious materials sufficiently state a colorable First Amendment free-exercise claim at the screening stage.
3. The amended complaint states a colorable RLUIPA claim against Captain Youker in his official capacity, but any individual-capacity RLUIPA claim is dismissed because RLUIPA does not permit money damages against prison officials in their individual capacities.
4. The allegations sufficiently state colorable First Amendment retaliation claims against Captain Youker in his individual capacity.
5. The allegations permit an inference that the alleged jail policies violated Tennessee Code Annotated § 41-21-211 and state a claim against Captain Youker in his official and individual capacities.

Questions Presented

1. Whether the amended complaint stated colorable First Amendment free-exercise and retaliation claims concerning the alleged prohibition and restricted access to Bibles.
2. Whether the amended complaint stated a colorable claim under RLUIPA based on the alleged substantial burden on Dalton’s religious exercise.
3. Whether the alleged Bible-access policy stated a claim under Tennessee Code Annotated § 41-21-211.
4. Whether Captain Youker could be sued in his individual and official capacities, including whether RLUIPA permits an individual-capacity damages claim.
5. Whether the supplemental complaint added defendants or claims and whether the emergency motion for injunctive relief should be resolved immediately.

Disposition

other