LONG V. SUGAI, No. 22-15997 (9th Cir. 2024)
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In the case at hand, DeWitt Lamar Long, a practicing Muslim and inmate at Halawa Correctional Facility in Hawaii, brought a legal action against several prison officials under 42 U.S.C. § 1983. He alleged that his First Amendment rights to freely exercise his religion were violated and that he was unconstitutionally retaliated against for engaging in protected First Amendment activity. Specifically, Long claimed that he was denied meals consistent with his Islamic faith, that his meal during Ramadan was delivered early and thus was cold and potentially unsafe by the time he could break his fast, and that he was transferred from a medium-security facility to a high-security facility in retaliation for filing grievances.
The United States Court of Appeals for the Ninth Circuit affirmed in part, reversed in part, and vacated in part the district court’s judgment. The appellate court found that the district court erred in dismissing Long's claims for injunctive relief without allowing him a chance to amend his complaint to demonstrate the need for such relief. The court also vacated the district court’s decision to grant summary judgment in favor of Sergeant Lee, holding that the delivery of Long's evening meal at 3:30 p.m. during Ramadan substantially burdened his free exercise of religion. The court remanded the case to allow the district court to evaluate whether the burden was justified.
However, the appellate court affirmed the district court's summary judgment in favor of Chief of Security Antonio regarding Long’s claim that he was transferred from a medium-security facility to a high-security facility in retaliation for filing grievances. The court agreed with the district court that the sequence of events leading to the transfer was insufficient to show retaliatory intent. The court also affirmed the district court’s judgment after a bench trial in favor of Sergeant Sugai and Chief of Security Antonio on Long’s free exercise of religion and retaliation claims.
Court Description: Prisoner Civil Rights. The panel affirmed in part, reversed in part, and vacated in part the district court’s judgment in favor of prison officials in an action brought pursuant to 42 U.S.C. § 1983 by Hawaii prison inmate DeWitt Lamar Long, a practicing Muslim, alleging that prison officials violated his First Amendment right to free exercise of religion and unconstitutionally retaliated against him for engaging in protected First Amendment activity.
The panel reversed the district court’s dismissal, at the screening stage, of Long’s claims for injunctive relief. Although Long’s pro se complaint alleged only past actions by defendants, his “Request for Relief” asked, among other things, that staff be properly trained and that Ramadan meals be served hot. The district court should have allowed Long to amend his complaint to allege facts showing a need for injunctive relief.
The panel vacated the district court’s summary judgment in favor of Sergeant Lee, holding that delivery of Long’s evening meal at 3:30 p.m. during Ramadan substantially burdened his free exercise of religion. The district court should have evaluated the four factors set forth in Turner v. Safley, 482 U.S. 78 (1987), to determine whether the burden was justified. The panel remanded to allow the district court to conduct that analysis.
The panel affirmed the district court’s partial summary judgment in favor of Chief of Security Antonio on Long’s claim that he was transferred from a medium-security facility to a high-security facility in retaliation for filing grievances. The panel agreed with the district court that the sequence of events leading to the transfer was insufficient to show retaliatory intent.
The panel affirmed the district court’ judgment, following a bench trial, in favor of Sergeant Sugai on Long’s free exercise of religion and retaliation claims, determining that ample evidence supported the district court’s findings.
Finally, the panel affirmed the district court’s judgment, following a bench trial, in favor of Chief of Security Antonio on Long’s free exercise claim. The district court did not err by concluding that (1) the substantial burden on Long’s free exercise rights caused by his transfer to a high-security facility was justified; and (2) Chief of Security Antonio was not authorized to arrange weekly transportation to a medium-security facility for religious services and therefore was not a proper defendant.
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