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Erik Maloney v. Charles Ryan
711 F. App'x 372
9th Cir.
2017
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Background

  • Plaintiff Erik Scott Maloney, an Arizona state prisoner, sued under 42 U.S.C. § 1983 and RLUIPA alleging interference with his Islamic religious practices in prison.
  • Claims included: (1) prison book policy restricting religious materials; (2) provision of breakfast after dawn but before sunrise during Ramadan; (3) alleged deprivation of lunches by defendant Mason over three days; and (4) denial of ability for group prayer before fasting (raised late).
  • District court dismissed or granted summary judgment on various claims; Maloney appealed pro se.
  • Appeals court reviews de novo dismissals and summary judgment and may affirm on any record-supported basis.
  • Court considered RLUIPA substantial-burden standards, qualified immunity for damages, mootness for injunctive relief after policy change, Eighth Amendment deliberate-indifference standard, and waiver of issues raised first on appeal.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
RLUIPA challenge to book policy Policy substantially burdens Maloney's religious exercise Policy does not impose a substantial burden on religious practice Dismissed: insufficient facts to show substantial burden
Damages for breakfast timing during Ramadan Serving breakfast after dawn violates religious rights; seeks damages Officials entitled to qualified immunity because law was not clearly established Damages dismissed: qualified immunity protects defendants
Injunctive relief for breakfast policy Seeks injunction to change meal timing Defendants voluntarily changed policy, mooting claims Injunctive claims moot due to voluntary cessation
Eighth Amendment — lunch deprivation by Mason Three-day lunch deprivation constituted cruel and unusual punishment No deliberate indifference shown; no genuine dispute of material fact Summary judgment for defendants: no deliberate indifference shown
RLUIPA claim re: group prayer before fast Prison prevented group prayer before fasting Claim not properly raised below; waived on appeal Waived for failure to raise in district court
Discovery motions Denial prejudiced Maloney's ability to prove claims Denial did not cause actual prejudice Denial was not an abuse of discretion

Key Cases Cited

  • Walker v. Beard, 789 F.3d 1125 (9th Cir. 2015) (elements of a RLUIPA claim and substantial-burden standard)
  • San Jose Christian Coll. v. City of Morgan Hill, 360 F.3d 1024 (9th Cir. 2004) (substantial burden requires significantly great restriction)
  • Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (qualified immunity requires clearly established law)
  • Saucier v. Katz, 533 U.S. 194 (2001) (qualified immunity analysis; reasonableness of legal mistake)
  • Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate-indifference standard)
  • Rosebrock v. Mathis, 745 F.3d 963 (9th Cir. 2014) (voluntary cessation and mootness factors)
  • Foster v. Runnels, 554 F.3d 807 (9th Cir. 2009) (sustained food deprivation can constitute cruel and unusual punishment)
  • Wilhelm v. Rotman, 680 F.3d 1113 (9th Cir. 2012) (standards for reviewing dismissals under §1915A)
Read the full case

Case Details

Case Name: Erik Maloney v. Charles Ryan
Court Name: Court of Appeals for the Ninth Circuit
Date Published: Oct 4, 2017
Citation: 711 F. App'x 372
Docket Number: 15-16898
Court Abbreviation: 9th Cir.