Derwin Jackson v. W. Sullivan, 692 F. App'x 437

Plaintiff Derwin Jules Jackson, a former inmate at California Correctional Institution (CCI Tehachapi), sued prison officials challenging restrictions imposed because he wore dreadlocks, seeking declaratory and injunctive relief and damages under RLUIPA and constitutional claims under the First and Eighth Amendments.
Procedural posture: District court granted summary judgment for defendants; Jackson appealed. The Ninth Circuit amended disposition: affirmed in part, reversed in part, remanded.
Jackson lost yard access for more than ten weeks in 2004 while in segregated housing; he alleges this prolonged exercise deprivation violated the Eighth Amendment.
Administrative appeals: two-level denials by officials Meadors and Cobbs; a later director-level review partially granted relief and ordered staff training and clarified that manual searches or handheld metal detectors should be used on dreadlocks.
RLUIPA damages: the court held RLUIPA does not authorize damages against officials in their official capacities (Sossamon) or individual capacities in this context, and Jackson’s equitable RLUIPA claims were moot because he suffered no continuing effects and the policy was revised.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Availability of RLUIPA damages / equitable relief	Jackson sought injunctive/declaratory relief and damages under RLUIPA for restriction on dreadlocks	Defendants argued qualified immunity and that RLUIPA does not permit damages here; any equitable relief is moot	RLUIPA damages unavailable; equitable RLUIPA claims moot — dismissal affirmed
Eighth Amendment (exercise deprivation)	Jackson argued >10 weeks without yard access constituted cruel and unusual punishment; officials deliberately indifferent	Defendants argued qualified immunity / security justification	Reversed as to Meadors and Cobbs: factual dispute on deliberate indifference and no qualified immunity; affirmed as to other defendants
First Amendment free exercise (screening dismissal)	Jackson alleged policy burdened religious exercise (dreadlocks)	Defendants argued regulation reasonably related to penological interests (security)	Screening affirmed: complaint did not plausibly state a Free Exercise claim under Turner standard
First Amendment access to courts / retaliation / property	Jackson claimed retaliation and denial of access to courts and property because of grievances	Defendants argued no actionable underlying claim for access and legitimate penological/regulatory reasons for property handling	Retaliation and access claims dismissed: retaliation lacked evidence of motive/entitlement; access claim lacked allegation of a nonfrivolous underlying claim

Hydrick v. Hunter, 669 F.3d 937 (9th Cir. 2012) (qualified immunity not available for claims seeking equitable relief)
Jones v. Williams, 791 F.3d 1023 (9th Cir. 2015) (equitable claims moot when inmate removed unless continuing effects or reasonable expectation of recurrence)
Alvarez v. Hill, 667 F.3d 1061 (9th Cir. 2012) (same principle on mootness for inmates)
Sossamon v. Texas, 563 U.S. 277 (2011) (RLUIPA does not authorize damages against states in their sovereign capacity)
Wood v. Yordy, 753 F.3d 899 (9th Cir. 2014) (limitations on RLUIPA damages against individuals)
Lopez v. Smith, 203 F.3d 1122 (9th Cir. 2000) (exercise restrictions longer than six weeks ordinarily support Eighth Amendment liability)
Thomas v. Ponder, 611 F.3d 1144 (9th Cir. 2010) (prolonged deprivation of exercise can meet objective Eighth Amendment standard)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard requires awareness of substantial risk of serious harm)
Holt v. Hobbs, 135 S. Ct. 853 (2015) (RLUIPA scope and standards distinguished from Free Exercise Clause)
Turner v. Safley, 482 U.S. 78 (1987) (prison regulations valid if reasonably related to legitimate penological interests)
Christopher v. Harbury, 536 U.S. 403 (2002) (access-to-courts claims require allegation of a nonfrivolous underlying claim)