Holland v. Goord
2014 U.S. App. LEXIS 13142
| 2d Cir. | 2014Background
- Holland, a Muslim inmate at Wende, refused to drink water to produce a urine sample during daylight hours of Ramadan when ordered under DOCS Directive 4937 (three-hour testing window; water limited to 8 oz/hour).
- Correctional staff denied his request to provide a sample after sunset and issued a misbehavior report; Holland was placed in keeplock and later found guilty at a disciplinary hearing and sentenced to 90 days keeplock (served 77 days before reversal).
- At the hearing Holland sought to call his imam to corroborate that drinking before sunset would violate his faith; the hearing officer refused as redundant and found no religious exception to the Directive.
- Holland sued under 42 U.S.C. § 1983 and RLUIPA seeking damages and injunctive relief for free exercise violations, due process (refusal to call witness), and retaliation; DOCS later amended Directive 4937 to permit scheduling urinalysis outside fasting periods.
- The district court granted summary judgment to defendants, finding only a de minimis burden on religious exercise and granting qualified immunity; on appeal the Second Circuit held the choice to drink water or face disciplinary action was a substantial burden to free exercise and vacated as to damages for the First Amendment claim but affirmed other claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ordering urine test within three hours and requiring water during Ramadan substantially burdened free exercise | Holland: forcing him to drink during fast or face keeplock substantially burdens his sincerely held Ramadan observance | Defendants: burden was de minimis; atonement (make-up fast) available; policy justified | Court: choice to drink or be disciplined is a substantial burden; vacated district court on free exercise damages and remanded |
| Whether defendants are entitled to qualified immunity on free exercise claim | Holland: right to religious exception was clearly established by precedent | Defendants: reasonable officers could believe Directive lawful; law not clearly established | Court: remanded for district court to address qualified immunity in light of holding; declined to resolve first on appeal |
| Whether RLUIPA claim entitles Holland to damages or injunctive relief | Holland: RLUIPA provides protection and relief for substantial burdens | Defendants: RLUIPA does not authorize monetary damages against states; DOCS amendment moots injunctive relief | Court: affirmed—no monetary damages under RLUIPA; injunctive relief moot due to policy change |
| Whether refusal to call imam violated due process | Holland: imam would corroborate religious claim; exclusion prejudiced defense | Defendants: imam testimony would be duplicative and unnecessary; hearing officer has discretion to limit witnesses | Court: affirmed—refusal permissible as imam would be redundant; no due process violation |
| Whether keeplock was retaliation for religious practice | Holland: disciplinary action was motivated by his religious observance | Defendants: action would have been taken regardless of motive under Directive | Court: affirmed—plaintiff failed to show protected conduct was a substantial or motivating factor in retaliation |
Key Cases Cited
- Salahuddin v. Goord, 467 F.3d 263 (2d Cir. 2006) (free exercise framework in prison context)
- Ford v. McGinnis, 352 F.3d 582 (2d Cir. 2003) (inmate right to religiously dictated diet; substantial burden)
- McEachin v. McGuinnis, 357 F.3d 197 (2d Cir. 2004) (denial of food to break fast may burden free exercise)
- Jolly v. Coughlin, 76 F.3d 468 (2d Cir. 1996) (choice between religious belief and keeplock constitutes substantial burden)
- Turner v. Safley, 482 U.S. 78 (1987) (prison regulation valid if reasonably related to legitimate penological interests)
- Wolff v. McDonnell, 418 U.S. 539 (1974) (due process rights in prison disciplinary hearings)
- Ponte v. Real, 471 U.S. 491 (1985) (limits on witnesses in prison disciplinary hearings)
- Sossamon v. Texas, 563 U.S. 277 (2011) (RLUIPA does not permit monetary damages against States)
- Russell v. Selsky, 35 F.3d 55 (2d Cir. 1994) (refusal to call redundant witnesses not constitutional violation)