Anson McFaul v. Daniel Valenzuela, 2012 U.S. App. LEXIS 12283

McFaul, a Texas prisoner, alleges denial of religious devotional items by prison officials for Celtic Druidism.
Claims include First Amendment free exercise, Equal Protection, and RLUIPA/TRFRA violations.
District court granted summary judgment for defendants; McFaul appealed pro se.
Spears hearing revealed McFaul’s belief and need for medallions/beads; policy limited religious medallions to $25.
District court adopted magistrate’s report finding no substantial burden, no reasonable alternatives, and neutral application.
McFaul challenged discovery rulings, denial of counsel, and magistrate-judge jurisdiction on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the policy limiting religious medallions to $25 violate Free Exercise?	McFaul argues items are essential to Celtic Druid practice.	Policy is neutral, rationally related to penological interests.	No; policy is reasonable and neutrally applied among inmates.
Do RLUIPA/TRFRA claims survive when burden on religious exercise is not substantial?	There is a substantial burden due to denial of items.	Record shows only minimal impact; burden not substantial.	Affirmative dismissal of RLUIPA/TRFRA claims.
Are there triable issues on Equal Protection?	Different treatment (Satanist got a higher-cost item) shows discrimination.	No evidence of discriminatory intent; monetary exception not proof of policy bias.	No genuine dispute of material fact; no equal-protection violation.
Was there a due process or retaliation violation?	Denial and statements show retaliation for grievances.	No causal link or protected-interest deprivation shown.	No due-process or retaliation claim established.
Was magistrate-judge jurisdiction properly utilized and discovery properly limited?	Discovery should be freer; lack of access taints case.	Judge properly used 28 U.S.C. 636 and related provisions; discovery limits proper.	Judicial procedures properly followed; no reversible error.

Hicks v. Garner, 69 F.3d 22 (5th Cir. 1995) (free exercise rights subject to legitimate penological interests)
Safley v. Clark? Safley, 482 U.S. 78 (1987) (prison regulations must be reasonably related to legitimate penological interests)
Mayfield v. TDCJ, 529 F.3d 599 (5th Cir. 2008) (security concerns are legitimate penological interests in religious-item cases)
O’Lone v. Estate of Shabazz, 482 U.S. 342 (1987) (limits on religious exercise may be upheld where alternatives exist)
Smith v. Allen, 502 F.3d 1255 (11th Cir. 2007) (substantial burden requires more than mere denial; context matters)
Sossamon v. Lone Star State of Tex., 560 F.3d 316 (5th Cir. 2009) (RLUIPA substantial burden analysis; later affirmed by Supreme Court)