Wood v. Yordy, No. 12-35336 (9th Cir. 2014)
Annotate this CasePlaintiff, an Idaho state prisoner, filed suit against individual prison officials under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., claiming that they had imposed an unwarranted burden on his exercise of religion. Prison officials curtailed plaintiff's opportunities for chapel access after they found out that he was utilizing the chapel facilities to further his romantic relationships with prison guards. The court joined its sister circuits and held that plaintiff may not seek damages against prison officials in their individual capacities principally because RLUIPA was enacted pursuant to Congress's constitutional powers under the Spending Clause, and the individual defendants are not recipients of any federal funds. In regards to plaintiff's First Amendment claim, there was insufficient evidence to create a material issue of fact as to a retaliatory motive. Accordingly, the court affirmed the district court's grant of summary judgment for defendants.
Court Description: Prisoner Civil Rights. The panel affirmed the district court’s grant of summary judgment in favor of prison officials in an action brought by an Idaho state prisoner under the Religious Land Use and Institutionalized Persons Act. The panel held that plaintiff could not seek damages under the Religious Land Use and Institutionalized Persons Act against prison officials in their individual capacities. The panel held that the Act does not authorize suits against a person in anything other than an official or governmental capacity because it was enacted pursuant to Congress’s constitutional powers under the Spending Clause, and the individual defendants were not recipients of any federal funds. The panel also affirmed the district court’s dismissal of plaintiff’s claims alleging he was retaliated against in violation of his First Amendment rights. The panel determined that there was insufficient evidence to create a material issue of fact as to a retaliatory motive.
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