Anthony Davila v. Robin Gladden
777 F.3d 1198
11th Cir.2015Background
- Anthony Davila, a federal prisoner and Santeria priest, sued prison chaplain Dr. Bruce Cox and warden Anthony Hayes after they refused to deliver to him personal Santeria beads and cowrie shells infused with “Ache,” which he received at his initiation and contends are essential for his religious practice.
- BOP policy (Program Statement 5360.09) requires religious items be purchased from approved vendors listed in the prison catalog; the catalog items are not Ache-infused.
- Prison officials denied Davila’s administrative requests to accept the items from his goddaughter (a Santeria priestess) citing security and resource concerns; Davila sued under the Free Exercise Clause, RFRA, and RLUIPA (RLUIPA claim dismissed below and not appealed).
- The district court dismissed RFRA money-damages claims against officials and later granted summary judgment to defendants on Davila’s First Amendment claims and on RFRA injunctive relief; Davila appealed.
- The Eleventh Circuit affirmed dismissal/summary judgment on First Amendment and damages issues but reversed summary judgment as to Davila’s RFRA claim for injunctive relief and remanded, finding genuine disputes on substantial burden, compelling interest, and least-restrictive-means.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether refusing to deliver Ache-infused beads and shells substantially burdens Davila’s religious exercise under RFRA | Davila: denial flatly prevents him from exercising core Santeria practice—wearing Ache-infused items—so it is a substantial burden | Defendants: policy is neutral and does not substantially burden because catalog alternatives exist | Court: Davila’s RFRA substantial-burden showing survives summary judgment; sincerity undisputed and denial more than incidental burden |
| Whether the prison’s prohibition furthers a compelling governmental interest under RFRA | Davila: defendants failed to prove the ban actually furthers security or cost interests; evidence is conclusory | Defendants: maintaining security and limiting contraband/costs are compelling interests that justify the ban | Court: defendants failed to carry burden at summary judgment; assertions speculative and unsupported by specific evidence—genuine factual disputes exist |
| Whether the blanket catalog-only rule is the least restrictive means under RFRA | Davila: prison could designate qualified Santeria vendors (e.g., his goddaughter) or use existing screening (e.g., for eyeglasses) at minimal cost | Defendants: program statement bars non-catalog sources; categorical rule is necessary for security/resources | Court: material disputes exist; Program Statement itself contemplates exceptions and defendants did not show categorical ban is least restrictive |
| Availability of money damages under RFRA and immunity defenses | Davila: RFRA’s “appropriate relief” authorizes money damages against federal officials | Defendants: Congress did not unequivocally waive sovereign immunity for money damages; alternatively, qualified immunity protects officials individually | Held: RFRA does not clearly waive federal sovereign immunity for official-capacity money damages; even assuming individual-capacity damages cognizable, defendants entitled to qualified immunity on these facts |
Key Cases Cited
- Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (Santeria recognized as religion entitled to protection)
- Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (RFRA standards; least-restrictive-means is demanding)
- Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418 (courts must scrutinize asserted harms when granting religious exemptions)
- Sossamon v. Texas, 563 U.S. 277 (interpretation of “appropriate relief” does not waive state sovereign immunity for money damages)
- Turner v. Safley, 482 U.S. 78 (prison regulations reasonably related to penological interests standard)
- Pell v. Procunier, 417 U.S. 817 (prison safety and order are compelling governmental interests)
- Thomas v. Review Bd. of Ind. Emp’t Sec. Div., 450 U.S. 707 (court’s role limited in assessing sincerity/centrality of religious beliefs)
- Emp’t Div., Dep’t of Human Resources of Or. v. Smith, 494 U.S. 872 (judicial restraint in assessing religious claims)
- Saucier v. Katz, 533 U.S. 194 (qualified immunity framework)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity procedural discretion)
- Rich v. Secretary, Fla. Dep’t of Corr., 716 F.3d 525 (prison security/cost claims require evidentiary support under RFRA)