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