Antoine Miles v. David Guice
688 F. App'x 177
| 4th Cir. | 2017Background
- Antoine Miles, a North Carolina prisoner and member of the Nation of Gods and Earths (NGE), sued state prison officials under 42 U.S.C. § 1983 alleging violations of RLUIPA, the First, Eighth, and Fourteenth Amendments after NGE was designated a Security Threat Group due to ties to the United Blood Nation.
- Miles sought accommodations to practice NGE religion: a vegan diet, fasting on NGE holy days, and access to NGE texts.
- Defendants moved for summary judgment; the district court granted it. Miles appealed the rulings on RLUIPA, Eighth Amendment, and Equal Protection claims and the denial of appointed counsel.
- The Fourth Circuit assumed NGE qualified as a religion for RLUIPA purposes but evaluated whether particular policies substantially burdened Miles’ religious exercise.
- The court found denial of accommodation for fasting constituted a substantial burden under RLUIPA, but lack of a vegan menu and limited access to texts did not.
- The court affirmed summary judgment on the Eighth Amendment and Equal Protection claims and the denial of appointment of counsel, but vacated and remanded the fasting RLUIPA claim for strict-scrutiny review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RLUIPA — vegan diet | Miles: denial of vegan diet substantially burdens religious exercise | Defs: vegan diet not required; policy does not substantially burden religion | Held: No substantial burden; summary judgment for defendants affirmed |
| RLUIPA — fasting | Miles: inability to fast on holy days substantially burdens religious exercise | Defs: fasting ban justified by security/management concerns | Held: District court erred by not applying strict scrutiny; grant vacated and remanded for strict-scrutiny analysis |
| RLUIPA — access to texts | Miles: restrictions on NGE texts substantially burden practice | Defs: texts were not subject to a blanket ban; policies reasonable | Held: No substantial burden; summary judgment for defendants affirmed |
| Eighth Amendment — food/nutrition | Miles: denial of requested diet/fasts showed cruel and unusual punishment | Defs: no deliberate indifference to serious medical/nutritional needs | Held: Miles failed to show deliberate indifference; claim dismissed and qualified immunity applies |
| Equal Protection | Miles: NGE treated differently than other religious groups | Defs: Other groups not similarly situated given NGE’s gang ties; no purposeful discrimination | Held: Miles failed to show similarly situated comparators or intentional discrimination; claim dismissed and qualified immunity applies |
| Appointment of Counsel | Miles: needed counsel due to complexity and restrictions | Defs: no exceptional circumstances warranting counsel | Held: Denial not an abuse of discretion; request denied |
Key Cases Cited
- Core Commc’ns, Inc. v. Verizon Md. LLC, 744 F.3d 310 (4th Cir. 2014) (standard of review for summary judgment)
- Lovelace v. Lee, 472 F.3d 174 (4th Cir. 2006) (RLUIPA burden and strict-scrutiny framework)
- Thomas v. Review Bd. of Ind. Emp’t Sec. Div., 450 U.S. 707 (1981) (definition of substantial burden on religious exercise)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard under Eighth Amendment)
- Veney v. Wyche, 293 F.3d 726 (4th Cir. 2002) (equal protection proof requirements for prisoners)
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity standard)
- Whisenant v. Yuam, 739 F.2d 160 (4th Cir. 1984) (standards for appointment of counsel in civil cases)
- Mallard v. U.S. Dist. Court for S. Dist. of Iowa, 490 U.S. 296 (1989) (limits on federal-court appointment of counsel)