Leahy v. ConantAnnotate this Case
An inmate representing himself sued the prison superintendent and chaplain for violating his religious rights by providing an inadequate halal diet, banning scented prayer oils, and not allowing him to have additional religious texts in his cell beyond the prison’s limit. He claimed these actions violated the Equal Protection Clause of both the Alaska Constitution and the federal Constitution, and the federal Religious Land Use and Institutionalized Persons Act (RLUIPA). The inmate also sought reimbursement for scented oils that the prison had destroyed. The superior court granted the prison officials’ motion for summary judgment and dismissed all of the inmate’s claims. The Alaska Supreme Court reversed summary judgment on the inmate’s RLUIPA claim regarding the halal diet because the inmate did not receive adequate guidance on how to file affidavits in opposition to the summary judgment motion. The Court also reversed summary judgment on the RLUIPA claim regarding scented oils because the prison officials failed to satisfy their burden of proving that banning such oils was the least restrictive means to address their substantial interest in maintaining prison security and health. The Court affirmed dismissal of the inmate’s claims regarding the religious book limit because the issue was not yet ripe. And the Court vacated the award of attorney’s fees and costs.