California prisoner Patrick Ronald Holley, Sr., brought suit pursuant to 42 U.S.C. § 1983 alleging that prison grooming regulations requiring short hair imposed a substantial burden on his exercise of religion in violation of section 3 of RLUIPA. He sought monetary damages from the defendant prison officials in their official capacities. The district court granted summary judgment to the defendants. On appeal, the Ninth Circuit affirmed the district court’s judgment.
While housed at the California Medical Facility, Holley faced disciplinary charges on several occasions for keeping his hair longer than permitted by the prison grooming regulations then in effect. Those regulations made no exceptions for sincerely held religious beliefs. (PLN readers should note that the grooming regulations at issue here were subsequently amended. Under the amended regulations, which went into effect in January 2006, prisoners may wear their hair long, irrespective of their religious beliefs).
Holley’s religious beliefs were amorphous, not adequately captured, he claimed, by any particular established dogma. Instead, Holley paid close attention to his “spirit.” Informed by his spirit, Holley believed that Numbers 6:3-5 in the Bible required him to refrain from cutting his hair.
In May 2004, Holley was cited for letting his hair grow too long. One month later, to avoid punishment, he cut his hair. After exhausting his administrative remedies, he filed suit.
On cross-motions for summary judgment, the district court held that the Eleventh Amendment bars official-capacity suits for damages under RLUIPA. It entered judgment for the defendants.
On appeal, the Ninth Circuit began by noting that a suit against state officials in their official capacities is equivalent to a suit against the State itself, and that the Eleventh Amendment bars such a suit unless Congress, acting under its power to enforce the Fourteenth Amendment, has abrogated state sovereign immunity or, alternatively, the state has (unambiguously) waived it.
The question presented by Holley’s case was whether California had waived its immunity to damages in RLUIPA suits by accepting federal prison funding.
Holley pointed to language in two federal statutes (RLUIPA itself, 42 U.S.C. § 2000cc-2 (a); and section 1003 of the Rehabilitation Act Amendments of 1986, 42 U.S.C. § 2000d-7) which, he argued, signified that California indeed had, when it accepted federal funds, waived its sovereign immunity. The Ninth Circuit had little trouble rejecting those arguments. See: Holley v. California Department of Corrections, 599 F.3d 1108 (9th Cir., 2010).
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Related legal case
Holley v. California Department of Corrections
|Cite||599 F.3d 1108 (9th Cir., 2010)|
|Level||Court of Appeals|