Decided: July 9, 2015
The Fourth Circuit held that the dismissal of Jehovah’s Sabbath claims, cell assignment claims, and deliberate indifference claim was inappropriate. Additionally, the Fourth Circuit held that the trial court erred in granting summary judgment to the Appellees regarding Jehovah’s communion wine claim. The district court’s judgment was reversed in its entirety and remanded back to the lower court.
Jehovah is an inmate who was incarcerated at Sussex I Prison (SIP) in Virginia when he filed this suit. Jehovah alleged in his complaint four separate actions taken by Virginia Department of Corrections (VDOC) employees that violated his rights under the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA). First, Jehovah claimed that certain prison policies have prevented him from taking communion in the manner required by his religious beliefs. The final VDOC policy did not allow prisoners to consume communion wine. Second, Jehovah claimed that he has not been able to obtain a job that will allow him to observe his Sabbaths. According to Jehovah, there are very few jobs at SIP that allow for prisoners to work and still observe the Sabbaths. Third, Jehovah claims that VDOC has housed him with nonbelievers and anti-Christians, contrary to his beliefs. Fourth, Jehovah alleged that he received several medical ailments that VDOC staff deliberately ignored. Jehovah filed this lawsuit seeking compensatory and injunctive relief for these alleged violations of RLUIPA, the First Amendment, and the Eighth Amendment.
On appeal, Jehovah argues that the district court erred in 1) dismissing his Sabbath, cell assignment, and deliberate indifference claims under § 1915A, and 2) granting Appellees summary judgment on his communion wine claim. RLUIPA requires a stricter protection of prisoners’ free exercise rights than does the First Amendment, applying “strict scrutiny instead of reasonableness.” Lovelace v. Lee, 472 F.3d 174, 186 (4th Cir. 2006). The Fourth Circuit determined the award of summary judgment on his communion wine claim was inappropriate because the district court did not allow Jehovah an opportunity to brief the court regarding whether the wine ban substantially burdened his religious exercise and the record was insufficient to support the conclusion that the wine ban was the least restrictive means to address the government’s purported security interest. The court found that a reasonable jury could rule in Jehovah’s favor regarding the communion wine issue.
The district court dismissed Jehovah’s Sabbath work claims because prisoners do not have a constitutional right to job opportunities while incarcerated. However, Jehovah correctly pointed out that the constitutional right being violated is his right to free exercise of his religious beliefs; the unavailability of prison jobs accommodating his Sabbath schedule is the alleged burden on that right. When stating a RLUIPA claim, Jehovah need only plead facts tending to show a substantial burden on his exercise of sincerely held religious beliefs. 42 U.S.C. § 2000cc-2(b). Here, Jehovah has alleged that his religious practice forbids him from working on the Sabbaths. The Fourth Circuit determined that Jehovah alleged enough facts that support a plausible claim for relief under the RLUIPA and the First Amendment and remanded the claim for further proceedings.
The district court dismissed Jehovah’s housing claims because it determined that Jehovah did not have a right to choose a cellmate based on that person’s religious background. However, again, the Fourth Circuit determined the proper inquiry is to what extent VDOC burdened Jehovah’s right to exercise his religious beliefs by assigning him cellmates who did not share his religious views. Jehovah claimed that he was harassed and burdened on account of his religious beliefs by being housed with these inmates. Additionally, Jehovah claimed that his housing assignments were deliberately done to harass him. Based on Jehovah’s claims, the Fourth Circuit held that Jehovah alleged enough facts that support a plausible claim for relief under the RLUIPA and the First Amendment and remanded the claim for further proceedings regarding his housing assignment.
In order to present a claim of deliberate indifference under the Eighth Amendment, the inmate must show “the deprivation of a basic human need was objectively sufficiently serious” and “subjectively the officials acted with a sufficiently culpable state of mind.” De’Lonta v. Angelone, 330 F.3d 630, 634 (4th Cir. 2003). Jehovah alleged constant chest pain, chronic headaches, and diminished hearing and eyesight. Additionally, Jehovah claimed he has been diagnosed with pulmonary hypertension, a serious and sometimes fatal condition. Jehovah received some treatment; however, his doctors ignored and failed to treat many of his symptoms. Sufficient factual allegations supporting a plausible claim for relief was presented by Jehovah and the Fourth Circuit held that the district court erred in dismissing Jehovah’s Eighth Amendment claim.
Austin T. Reed