Stephen Barry Gibbons v. Sabanda

Summary

The United States District Court for the Western District of Pennsylvania overruled Stephen Barry Gibbons’s objections to a magistrate judge’s Report and Recommendation. The court adopted the recommendation, denied Gibbons’s motion for summary judgment, and granted Defendant Sabanda’s motion for summary judgment in claims concerning religious exercise, the Religious Freedom Restoration Act, and processing of a religious-preference change.

Holdings

1. Timely objections require the district court to conduct a de novo determination of the portions of the magistrate judge's Report and Recommendation to which objection is made; after conducting that review, the court overruled Gibbons's objections and adopted the recommendation.
2. The Religious Freedom Restoration Act does not apply to state and local governments.
3. Sabanda could not be held legally responsible for Gibbons's change in religious preference because Sabanda was not personally involved in the conduct that caused the change.
4. Summary judgment for Sabanda was appropriate because the undisputed facts showed that Sabanda did not unduly burden Gibbons's religious practice and processed the religious-preference request within the thirty-day period required by DOC policy.

Questions Presented

1. Whether the district court should reject the magistrate judge's recommendation after de novo review of Gibbons's objections.
2. Whether the Religious Freedom Restoration Act applies to state and local governments.
3. Whether Sabanda could be held legally responsible for Gibbons's change in religious preference when Sabanda lacked personal involvement in the change.
4. Whether the undisputed facts established that Sabanda did not unduly burden Gibbons's exercise of religion and was entitled to summary judgment.

Disposition

other