DeLoney v. Snyder
3:16-cv-00732
D. Nev.Oct 10, 2017Background
- Plaintiff Donald Deloney, an inmate at Warm Springs Correctional Center (WSCC), sued Chaplain Richard Snyder under 42 U.S.C. § 1983 alleging interference with Muslim services, retaliation, RLUIPA and First Amendment violations.
- Deloney was the inmate facilitator for Muslim services; he alleges Snyder imposed an unwritten rule requiring a handwritten script one week in advance and threatened discipline for deviation.
- Plaintiff alleges Snyder twice barred him from speaking for failing to submit scripts, then removed him from the facilitator role after Plaintiff grieved the treatment; Plaintiff also alleges unequal treatment of Muslim versus Christian inmate communication and refusal to adjust Friday prayer times.
- Plaintiff moved for injunctive relief asking Snyder be removed from duties and for resumption of Islamic services, asserting Snyder suspended services until an outside Imam could be found.
- Snyder responded that Deloney was transferred to Northern Nevada Correctional Center in July 2017; the magistrate judge found injunctive claims moot because Deloney showed no reasonable expectation of return to WSCC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether preliminary injunctive relief is warranted to restore Muslim services and remove Snyder from duties | Deloney: Snyder suspended services and imposed unlawful restrictions; immediate relief necessary to protect religious exercise | Snyder: Services not permanently cancelled; Deloney was transferred and thus lacks ongoing injury at WSCC | Denied as moot — transfer eliminated live controversy and no reasonable expectation of return |
| Whether Deloney likely to succeed on First Amendment/RLUIPA claims | Deloney: Written directives and suspensions burdened religious exercise and retaliated against him | Snyder: Disputes full cancellation and factual assertions | Court: Found plaintiff had a strong argument on merits but did not reach relief because of mootness |
| Applicability of PLRA constraints on injunctive relief | Deloney: seeks court-ordered corrections to prison practices | Snyder: emphasized deference to prison administration and impact concerns under PLRA | Court applied PLRA standards in assessing scope of injunctive relief (narrowly drawn, least intrusive) but denied relief as moot |
| Mootness doctrine for prison injunctive claims after transfer | Deloney: did not show expectation of return to WSCC | Snyder: transfer mooted injunctive request | Held: Motion moot; exception "capable of repetition yet evading review" inapplicable absent reasonable expectation of return |
Key Cases Cited
- University of Texas v. Camenisch, 451 U.S. 390 (1981) (purpose of preliminary injunction is to preserve status quo pending resolution on the merits)
- Munaf v. Geren, 553 U.S. 674 (2008) (preliminary injunction is extraordinary relief and not awarded as of right)
- Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) (four-part Winter test for preliminary injunctions)
- Gilmore v. People of the State of California, 220 F.3d 987 (9th Cir. 2000) (PLRA limits scope of injunctive relief in prisons)
- Johnson v. Moore, 948 F.2d 517 (9th Cir. 1991) (transfer of prisoner generally moots request for injunctive relief absent reasonable expectation of return)
- Murphy v. Hunt, 455 U.S. 478 (1982) (‘‘capable of repetition yet evading review’’ exception to mootness limited to cases with reasonable expectation of recurrence)