Summary
The court partially grants and partially denies defendants' motion for summary judgment in Reonte C. Moore's First Amendment free-exercise action concerning the denial and delayed delivery of Islamic religious materials while he was housed in restrictive housing. Summary judgment is granted to Dennis Davis, Joseph Cooper, Stephen Foster, and Austin Harmon for lack of personal involvement, but denied as to Chance Bishop because a reasonable jury could find that the deprivation substantially burdened Moore's religious practices without a sufficient penological justification. The court also addresses potential limits on damages under the Prison Litigation Reform Act and directs a magistrate judge to confer with the parties regarding next steps.
Questions Presented
- Whether defendants Davis, Cooper, Foster, and Harmon were entitled to summary judgment because the evidence did not establish their personal involvement in the alleged deprivation of Moore's religious property.
- Whether the evidence permitted a reasonable jury to find that Bishop substantially burdened Moore's religious practices and lacked a legitimate penological justification for the continued denial or delay of his religious materials.
- Whether the defendants were entitled to summary judgment on Moore's First Amendment free-exercise claim.
Holdings
- A § 1983 plaintiff must establish that each defendant was personally responsible for the deprivation of a constitutional right. Because the evidence showed that Davis, Cooper, Foster, and Harmon had no role in collecting, inventorying, storing, or distributing Moore's property, they were entitled to summary judgment.
- Summary judgment was inappropriate as to Bishop because the evidence would permit a reasonable jury to find that denial of Moore's prayer rug, Quran, and other religious materials substantially burdened his religious practices and that Bishop had not established a legitimate penological reason for the additional delay after Moore left the strip-cell range.
- On summary judgment, the court must view the evidence and draw reasonable inferences in favor of the nonmoving party and may not weigh evidence or make credibility determinations.