Booker v. Graham, 974 F.3d 101

Background

In July–August 2013 Auburn Correctional Facility imposed a five-day, security-motivated lockdown that coincided with Ramadan; inmates were confined to cells and given generic cold meals.
Plaintiff Amin Booker, a Nation of Islam adherent, alleged the lockdown prevented Suhoor, communal evening halal meals, ritual bathing, and group prayer required by his faith.
After Ramadan ended, Auburn officials transferred Booker to the Special Housing Unit (SHU) for ~one month; Booker says the transfer was retaliatory for grievances he filed about the lockdown; officials cited distribution of violent strike fliers.
Booker sued under the First Amendment Free Exercise Clause, RLUIPA (seeking injunctive/declaratory relief), and brought a retaliation claim; the district court granted summary judgment to defendants on Free Exercise and RLUIPA; Booker lost at trial on retaliation.
On appeal the Second Circuit affirmed: granted qualified immunity to defendants on Free Exercise claims, held RLUIPA claims moot by Booker’s transfer, and found the district court properly admitted contested trial evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Free Exercise — lockdown restrictions during Ramadan	Booker: lockdown substantially burdened his religious observance and required accommodation (halal meals, group prayer, ritual bathing).	Defendants: lockdown served legitimate penological/security purpose; no clearly established duty to accommodate during safety-motivated lockdown.	Court: Qualified immunity; no clearly established law requiring accommodation in a facility-wide security lockdown.
Free Exercise — SHU denial of congregate prayer	Booker: SHU confinement deprived him of group prayer, a protected practice.	Defendants: SHU rules bar congregate services for security; no clearly established right to attend group prayer in SHU.	Court: Qualified immunity; prison and state regulations permitting ban on congregate services support defendants.
RLUIPA injunctive/declaratory relief	Booker: seeks relief for interference with Ramadan observance and SHU application.	Defendants: RLUIPA relief is injunctive/declaratory only; Booker has been transferred so claims are moot.	Court: RLUIPA claims moot because Booker was transferred from Auburn and speculative return does not preserve claims.
Evidentiary rulings at retaliation trial	Booker (pro se): district court wrongly admitted hearsay of gang affiliation and criminal/disciplinary history, warranting new trial.	Defendants: evidence admissible to show motive and for impeachment/character; not offered for its truth.	Court: No abuse of discretion; statements admitted to show defendants’ motivation and criminal/disciplinary records were proper under the rules.

Key Cases Cited

White v. Pauly, 137 S. Ct. 548 (2017) (qualified immunity standard governs when conduct does not violate clearly established rights)
Kisela v. Hughes, 138 S. Ct. 1148 (2018) (existing precedent must place constitutional question beyond debate for right to be clearly established)
McGowan v. United States, 825 F.3d 118 (2d Cir. 2016) (review qualified immunity by considering precedent as of the challenged conduct)
Ford v. McGinnis, 352 F.3d 582 (2d Cir. 2003) (inmate right to diet consistent with religious scruples)
O’Lone v. Estate of Shabazz, 482 U.S. 342 (1987) (prison regulations that are reasonably related to penological interests do not violate Free Exercise)
Turner v. Safley, 482 U.S. 78 (1987) (deference to corrections officials where accommodation has significant "ripple effects")
Salahuddin v. Jones, 992 F.2d 447 (2d Cir. 1993) (upholding prohibition on congregate services when inmate poses security risk)
Washington v. Gonyea, 731 F.3d 143 (2d Cir. 2013) (RLUIPA does not authorize monetary damages; provides injunctive/declaratory relief)
Salahuddin v. Goord, 467 F.3d 263 (2d Cir. 2006) (transfer generally moots inmate claims for injunctive/declaratory relief against facility officials)
Shepherd v. Goord, 662 F.3d 603 (2d Cir. 2011) (speculation about possible return to facility does not prevent mootness)
Cameron v. City of New York, 598 F.3d 50 (2d Cir. 2010) (district court evidentiary rulings reviewed for abuse of discretion)