Brandon Jackson v. Richard Arnold, David Mitchell, and Rob Jeffreys

Summary

The court grants summary judgment to Warden David Mitchell and Assistant Warden Rob Jeffreys because they lacked personal involvement in the alleged constitutional violation before Ramadan 2022 ended. It denies summary judgment to Chaplain Richard Arnold, finding a genuine factual dispute over whether providing Ramadan sign-up notice only through the institutional television channel substantially burdened Plaintiff Brandon Jackson’s religious exercise. The case proceeds to a bench trial on Jackson’s request for policy change and declaratory or equitable relief.

Holdings

1. Mitchell and Jeffreys were entitled to summary judgment because the record established that they did not learn of the Ramadan sign-up incident until after the 2022 Ramadan observance had ended, and § 1983 liability requires personal involvement rather than respondeat superior liability.
2. A genuine dispute of material fact existed as to whether providing Ramadan sign-up information solely through an institutional television channel adequately informed Jackson of the deadline and therefore comported with the First Amendment's free-exercise protection in the prison context.
3. Defendants were not entitled to qualified immunity at the summary-judgment stage because the evidence raised a factual dispute concerning a First Amendment violation and the right of a prisoner not to have religious exercise substantially burdened without justification was clearly established.
4. Jackson's request for a policy change was construed as a request for declaratory relief and was not defeated by his lack of a claim for monetary damages.

Questions Presented

1. Whether summary judgment was proper for Warden David Mitchell and Assistant Warden Rob Jeffreys where the record showed they learned of the Ramadan sign-up issue only after the 2022 observance had ended.
2. Whether summary judgment was proper for Chaplain Richard Arnold where the only Ramadan sign-up notice was broadcast on institutional television and the record created a factual dispute about whether the notice adequately informed Jackson of the deadline.
3. Whether defendants were entitled to qualified immunity on Jackson's First Amendment free-exercise claim.
4. Whether Jackson's request for policy change could proceed as a request for declaratory or equitable relief despite his lack of a claim for monetary damages.

Disposition

other