Zajrael v. Harmon, et al., No. 11-1180 (8th Cir. 2012)
Annotate this CasePlaintiff, an Arkansas inmate, sued officials of the Arkansas Department of Corrections under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc-1 et seq., and 42 U.S.C. 1983, alleging violations of his statutory and constitutional rights. Defendant, whose religious practice incorporated elements of Christianity, Islam, and Buddhism, alleged that correctional officers seized a prayer cap, prayer rugs, thikr beads, and prayer oil from his cell, as well as religious texts and books. His amended complaint alleged that these actions violated his rights under RLUIPA and the First Amendment. The court held that section 1983 provided no cause of action against agents of the State acting in their official capacities and therefore, sovereign immunity barred plaintiff's claims for damages under RLUIPA. The court further held that plaintiff's claim for injunctive relief was moot because he was transferred out of that facility. Because plaintiff was no longer subject to the policies that he challenged, there was no live case or controversy.
Court Description: Prisoner case - Prisoner civil rights. Section 1983 provides no cause of action against agents of the State acting in their official capacity; sovereign immunity barred plaintiff's claim for damages under the Religious Land Use and Institutionalized Persons Act; claim for injunctive relief under the Act was mooted by plaintiff's transfer to a different institution.
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