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Fourth Circuit Holds Individual Capacity Damage Claims Unavailable Under RLUIPA
The Fourth Circuit Court of Appeals has held that the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. §§ 2000cc et seq., does not authorize individual capacity damages actions.
The Court’s ruling came in the appeal of prisoner Scott Lewis Rendelman, who brought a RLUIPA claim against the Maryland Department of Corrections (MDOC) for failing to provide him with a kosher diet at MCI-Hagerstown.
While in MDOC custody, Rendelman was informed that a kosher diet was not available. Instead, to meet the kosher dietary laws of Rendelman’s Orthodox Jewish religious beliefs, the MDOC offered prisoners a choice of two diets: a pork-free regular diet and a lacto-ovo vegetarian diet.
Although the diets were designed “to accommodate a broad spectrum of religious practices,” neither diet complied with the kashrut (the rules derived from the Torah governing food). This resulted in Rendelman being unable to eat many meals, causing him to lose 30 pounds.
The district court, in granting the defendants’ motion for summary judgment, held that prison officials did not violate the First Amendment or RLUIPA. On appeal, the Fourth Circuit dismissed Rendelman’s injunctive relief claim seeking a kosher diet.
The basis for the dismissal was that Rendelman had been transferred to federal custody. Additionally, as the MDOC was changing its food policies to provide a kosher diet, it was unlikely the problem was capable of repetition.
Turning to Rendelman’s claim for monetary damages, the appellate court noted his allegations were against individual prison officials and not the state itself. The Court of Appeals held that such damages are not allowed by RLUIPA, which applies to the states under the spending clause.
“Legislation enacted pursuant to Congress’ spending power has previously been held to authorize damages actions against state entities receiving federal funds,” the Fourth Circuit wrote. “Our research suggests, however, that it would be a novel use of the spending clause to condition the receipt of federal funds on the creation of an individual capacity damages action; we can find no instance in which the spending clause has been used in this manner.”
RLUIPA also purports to have an independent basis under the commerce clause, but that issue was not before the Court. As such, Rendelman’s appeal was dismissed in part and the district court’s summary judgment order was affirmed in part. See: Rendelman v. Rouse, 569 F.3d 182 (4th Cir. 2009).
The Court’s ruling came in the appeal of prisoner Scott Lewis Rendelman, who brought a RLUIPA claim against the Maryland Department of Corrections (MDOC) for failing to provide him with a kosher diet at MCI-Hagerstown.
While in MDOC custody, Rendelman was informed that a kosher diet was not available. Instead, to meet the kosher dietary laws of Rendelman’s Orthodox Jewish religious beliefs, the MDOC offered prisoners a choice of two diets: a pork-free regular diet and a lacto-ovo vegetarian diet.
Although the diets were designed “to accommodate a broad spectrum of religious practices,” neither diet complied with the kashrut (the rules derived from the Torah governing food). This resulted in Rendelman being unable to eat many meals, causing him to lose 30 pounds.
The district court, in granting the defendants’ motion for summary judgment, held that prison officials did not violate the First Amendment or RLUIPA. On appeal, the Fourth Circuit dismissed Rendelman’s injunctive relief claim seeking a kosher diet.
The basis for the dismissal was that Rendelman had been transferred to federal custody. Additionally, as the MDOC was changing its food policies to provide a kosher diet, it was unlikely the problem was capable of repetition.
Turning to Rendelman’s claim for monetary damages, the appellate court noted his allegations were against individual prison officials and not the state itself. The Court of Appeals held that such damages are not allowed by RLUIPA, which applies to the states under the spending clause.
“Legislation enacted pursuant to Congress’ spending power has previously been held to authorize damages actions against state entities receiving federal funds,” the Fourth Circuit wrote. “Our research suggests, however, that it would be a novel use of the spending clause to condition the receipt of federal funds on the creation of an individual capacity damages action; we can find no instance in which the spending clause has been used in this manner.”
RLUIPA also purports to have an independent basis under the commerce clause, but that issue was not before the Court. As such, Rendelman’s appeal was dismissed in part and the district court’s summary judgment order was affirmed in part. See: Rendelman v. Rouse, 569 F.3d 182 (4th Cir. 2009).
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Related legal case
Rendelman v. Rouse
| Year | 2009 |
|---|---|
| Cite | 569 F.3d 182 (4th Cir. 2009) |
| Level | Court of Appeals |
| Injunction Status | N/A |