Fuqua v. Ryan, No. 16-15597 (9th Cir. 2018)
Annotate this CasePlaintiff, a devout Christian, alleged violations of his right to religious liberty under the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc-1, and the denial of due process. In this case, plaintiff committed a disciplinary violation and was terminated from his kitchen assignment job after he refused to work on a religious holiday. The Ninth Circuit held that plaintiff's two inmate letters did not exhaust his administrative remedies, but that he exhausted administrative remedies through the disciplinary process. The panel held that defendants did not consider plaintiff's request for accommodation and RLUIPA mandated consideration of the requested accommodation. Finally, in regard to the district court's dismissal of certain defendants at the screening stage under 28 U.S.C. 1915A, the panel held that plaintiff's complaint did not explain how the dismissed defendants violated his rights under the First Amendment or RLUIPA. Therefore, the panel reversed the district court's ruling that plaintiff failed to exhaust his available administrative remedies; affirmed the section 1915A screening decision; and remanded for consideration of the merits of plaintiff's First Amendment and RLUIPA claims.
Court Description: Prisoner Civil Rights. The panel affirmed the district court’s dismissal of certain defendants pursuant to 28 U.S.C. § 1915A and reversed the district court’s summary judgment and remanded in a 42 U.S.C. § 1983 action brought by an Arizona prison inmate alleging violations of his right to religious liberty under the First Amendment and the Religious Land Use and Institutionalized Persons Act, 42 U.S.C. § 2000cc-1, and the denial of due process. Plaintiff is a devout Christian who was convicted of a disciplinary violation and terminated from his kitchen job assignment after he refused to work on a religious holiday. The district court found that plaintiff did not satisfy the exhaustion requirements of the Prison Litigation Reform Act because he initiated, but failed to complete, the grievance procedure by filing two inmate letters requesting an adjustment in his work schedule. The district court further determined that plaintiff’s appeal of his disciplinary conviction did not satisfy the exhaustion requirement because his religious accommodation claim was not within the scope of, nor addressed on the merits by, his disciplinary appeal. The panel held that although plaintiff’s letters requesting a work schedule adjustment did not suffice to exhaust administrative remedies, plaintiff sufficiently exhausted his administrative remedies through the disciplinary process. The 4 FUQUA V. RYAN panel noted that plaintiff had completed every step of the disciplinary appeal process and repeatedly voiced his need for religious accommodation. There was nothing ambiguous about plaintiff’s request; defendants were clearly on notice of the relief he sought. The panel concluded that on this record, the purposes of the exhaustion requirement had been fully served, and that plaintiff was not required to pursue a separate administrative grievance on his religious accommodation claim while simultaneously pursuing his disciplinary appeal. The panel affirmed the district court’s decision to dismiss certain defendants at the screening stage pursuant to 28 U.S.C. § 1915A, holding that plaintiff’s complaint had not explained how the dismissed defendants violated his rights under the First Amendment or the Religious Land Use and Institutionalized Persons Act.
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