Wiggins v. Griffin, et al., No. 21-533 (2d Cir. 2023)
Annotate this Case
Plaintiff a practicing Baptist, was incarcerated in the Green Haven Correctional Facility from 2002 until 2018. After prison officials failed to update the Protestant services “call-out list,” Wiggins was excluded from all religious services for over five months. He sued Green Haven officials Thomas Griffin, M. Kopp, D. Howard, and Dr. G. Jebamani under 42 U.S.C. Section 1983, alleging that they violated his constitutional rights. The district court granted Defendants’ motion for summary judgment, reasoning that (1) Defendants did not substantially burden Plaintiff’s free exercise of religion, (2) Defendants were entitled to qualified immunity, and (3) if there were a constitutional violation, Kopp was not personally involved in it.
The Second Circuit affirmed in part, vacated in part, and remanded to the district court for further proceedings. First, the court concluded that Defendants’ failure to update the Protestant services call-out list, which prevented Plaintiff from attending worship services for over five months, substantially burdened his religious exercise. Second, because disputed issues of material fact remain, qualified immunity cannot shield Defendants from liability at this juncture. Third, Plaintiff sufficiently alleged Kopp’s personal involvement in a First Amendment violation by pleading that Kopp took no action even after she was informed that Plaintiff’s rights were being infringed. Finally, the court held that a Section 1983 free exercise claim requires a plaintiff to demonstrate the defendant’s deliberate indifference to the plaintiff’s rights.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.