James Coleman v. Lincoln Parish Detention Ctr, et
858 F.3d 307
| 5th Cir. | 2017Background
- James Coleman, a Louisiana prisoner, filed a pro se 42 U.S.C. § 1983 complaint IFP alleging violations including RLUIPA/First Amendment (denial of Jumu’ah), denial of medical care, mail interference, denial of access to courts, equal protection violations, and retaliation.
- By filing, Coleman had been transferred from Lincoln Parish Detention Center (LPDC) to Jefferson Parish Detention Center; he sought declaratory and injunctive relief and named several detention officials.
- District court dismissed the complaint as frivolous and for failure to state a claim under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b)(1); Coleman appealed.
- Coleman’s RLUIPA injunctive/declaratory claims were moot due to his transfer; speculative possibility of return was insufficient for relief, and RLUIPA does not permit private suits for compensatory/punitive damages against officials.
- Coleman identified no broader burden on his religious exercise beyond being denied Jumu’ah attendance; his other claims were not (adequately) briefed and deemed abandoned.
- Coleman failed to move for leave to file a proposed third amended complaint; that filing had no legal effect. The dismissal counts as a strike under 28 U.S.C. § 1915(g), barring future IFP filings absent imminent danger.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of RLUIPA injunctive/declaratory relief | Coleman sought injunctive/declaratory relief concerning LPDC practices | Transfer to Jefferson Parish mooted requests; return speculative | Moot: transfer moots injunctive/declaratory RLUIPA claims |
| RLUIPA monetary damages against officials | Coleman sought compensatory/punitive damages under RLUIPA | RLUIPA does not authorize private monetary damages against officials | Denied: RLUIPA does not provide for such damages against individuals or officials |
| First Amendment (denial of Jumu’ah) | Coleman claimed denial to attend Jumu’ah violated free exercise | No other restrictions shown on religious exercise; denial limited | Dismissed: claim fails—insufficient showing of substantial burden |
| Other claims (medical, mail, access, equal protection, retaliation) | Alleged various constitutional violations | Defendants argued dismissal; issues not substantively briefed on appeal | Abandoned: not adequately briefed, thus dismissed |
| Amendment via proposed third amended complaint | Coleman submitted a proposed third amended complaint and proposed order | No formal motion showing good cause; procedural rules not followed | Ineffective: proposed amendment had no legal effect (no leave granted) |
| IFP strike under § 1915(g) | Coleman sought to avoid strike designation | Multiple prior dismissals qualify as strikes; current dismissal is a strike | Affirmed: dismissal counts as a strike; Coleman barred from IFP filings while incarcerated unless imminent danger |
Key Cases Cited
- Samford v. Dretke, 562 F.3d 674 (5th Cir. 2009) (standard of review for §1915 dismissals)
- Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings construed liberally)
- Taylor v. Books A Million, Inc., 296 F.3d 376 (5th Cir. 2002) (conclusory allegations insufficient)
- Cooper v. Sheriff, Lubbock Cty., 929 F.2d 1078 (5th Cir. 1991) (RLUIPA standing/relief principles)
- Herman v. Holiday, 238 F.3d 660 (5th Cir. 2001) (transfer moots injunctive relief absent reasonable likelihood of return)
- Sossamon v. Lone Star State of Tex., 560 F.3d 316 (5th Cir. 2009) (RLUIPA damages limitations)
- O’Lone v. Estate of Shabazz, 482 U.S. 342 (1987) (prison regulations and free exercise analysis)
- Yohey v. Collins, 985 F.2d 222 (5th Cir. 1993) (appellants must brief issues to preserve them)
- Brinkmann v. Dallas Cty. Deputy Sheriff Abner, 813 F.2d 744 (5th Cir. 1987) (pro se must address merits to preserve appeal)
- Thomas v. Chevron, 832 F.3d 586 (5th Cir. 2016) (motion for leave to amend must show good cause)
- United States ex rel. Mathews v. HealthSouth Corp., 332 F.3d 293 (5th Cir. 2003) (failure to obtain leave renders amended complaint legally ineffective)
- United States v. Jenkins, 780 F.2d 518 (5th Cir. 1986) (pro se litigants must follow procedural rules)
- Adepegba v. Hammons, 103 F.3d 383 (5th Cir. 1996) (prior dismissals may count as strikes under §1915(g))