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Third Circuit Holds No RLUIPA Damages
The Third Circuit Court of Appeals upheld a judgment for prison officials on a Pennsylvania prisoner's religious freedom claims.
Pennsylvania prisoner Shawn Sharp is a Sunni Muslim who "identifies himself as a member of the Habashi sect."
"Jumah is a group prayer service held on Fridays that every Muslim is obligated to attend if possible. Taleem is a religious study period that is generally held on a weekly basis though there is no religious obligation to attend."
Sharp regularly attended Jumah services and Taleem classes for Sunni Muslims offered by Chaplain Tanko Ibrahiym between 1998 and 2004. At some point, however, Sharp claimed ideological differences between his sect and the prison's recognized Sunni group.
On October 14, 1999, Sharp sought separate Jumah service and Taleem classes for his sect. He repeated his request on November 28, 1999. Two days later, Sharp was placed in administrative custody. Prison officials claimed that his efforts to organize a separate religious group created a security threat.
Sharp brought federal suit on November 2, 2000, alleging, inter alia, that failing to accommodate his Habashi sect violated the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA).
Sharp was transferred to another prison on May 23, 2001. He again sought accommodation of his Habashi sect on September 30, 2002 but the request was denied on December 18, 2002.
After several years of litigation, most of Sharp's claims were dismissed. At the conclusion of a 2008 bench trial on Sharp's First Amendment and RLUIPA claims, the district court ruled against him on both claims.
The Third Circuit affirmed. The court first agreed that Sharp's transfer mooted his RLUIPA injunctive relief claim. As a matter of first impression, the court joined several other Circuits in holding that RLUIPA does not allow individual damage claims.
The court then agreed that Defendants are entitled to qualified immunity on Sharp's First Amendment claim. While not affecting the outcome, the court concluded that the burden was erroneously placed on Sharp "to demonstrate that the denial of his request had no rational connection to any legitimate penological interest." See: Sharp v. Johnson, 669 F.3d 144 (3d Cir. 2012).
Pennsylvania prisoner Shawn Sharp is a Sunni Muslim who "identifies himself as a member of the Habashi sect."
"Jumah is a group prayer service held on Fridays that every Muslim is obligated to attend if possible. Taleem is a religious study period that is generally held on a weekly basis though there is no religious obligation to attend."
Sharp regularly attended Jumah services and Taleem classes for Sunni Muslims offered by Chaplain Tanko Ibrahiym between 1998 and 2004. At some point, however, Sharp claimed ideological differences between his sect and the prison's recognized Sunni group.
On October 14, 1999, Sharp sought separate Jumah service and Taleem classes for his sect. He repeated his request on November 28, 1999. Two days later, Sharp was placed in administrative custody. Prison officials claimed that his efforts to organize a separate religious group created a security threat.
Sharp brought federal suit on November 2, 2000, alleging, inter alia, that failing to accommodate his Habashi sect violated the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA).
Sharp was transferred to another prison on May 23, 2001. He again sought accommodation of his Habashi sect on September 30, 2002 but the request was denied on December 18, 2002.
After several years of litigation, most of Sharp's claims were dismissed. At the conclusion of a 2008 bench trial on Sharp's First Amendment and RLUIPA claims, the district court ruled against him on both claims.
The Third Circuit affirmed. The court first agreed that Sharp's transfer mooted his RLUIPA injunctive relief claim. As a matter of first impression, the court joined several other Circuits in holding that RLUIPA does not allow individual damage claims.
The court then agreed that Defendants are entitled to qualified immunity on Sharp's First Amendment claim. While not affecting the outcome, the court concluded that the burden was erroneously placed on Sharp "to demonstrate that the denial of his request had no rational connection to any legitimate penological interest." See: Sharp v. Johnson, 669 F.3d 144 (3d Cir. 2012).
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Related legal case
Sharp v. Johnson
| Year | 2012 |
|---|---|
| Cite | 669 F.3d 144 (3d Cir. 2012) |
| Level | Court of Appeals |