James Turner v. Gary Hamblin, 590 F. App'x 616

James Turner, a Muslim inmate at Columbia Correctional Institution, sues staff for First Amendment free exercise and RLUIPA violations seeking punitive damages.
Policy requires congregate services in Wisconsin prisons to be led by approved staff or non-inmate leaders; inmates cannot lead services.
Columbia uses Muslim volunteers to lead Islamic services; two Muslim chaplains exist but are not assigned to Columbia.
Over five years, Islamic Jumuah and Taleem services were canceled more than 120 times due to lack of Muslim volunteers; Christian services were canceled far fewer times.
District court granted summary judgment, rejecting RLUIPA claim and finding no clearly established First Amendment violation; Turner withdrew RLUIPA claim.
On appeal, Turner challenges qualified immunity, Establishment Clause reasoning, and the district court’s handling of the RLUIPA withdrawal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether qualified immunity bars Free Exercise claim	Turner asserts clearly established right to free exercise was violated by banning inmate-led services.	Staff acted under reasonable penological interests; no clearly established right violated.	Yes; qualified immunity blocks the Free Exercise claim.
Whether policy discriminates against Muslims under Establishment Clause	Turner argues disparate treatment of Islamic services shows religious bias.	Disparity is explained by security rationale; no discriminatory intent shown.	No; Establishment Clause claim fails.
Whether the district court erred in not reviving the withdrawn RLUIPA claim	Turner contends RLUIPA declaratory relief remains viable and district court misled him.	Court correctly refused to revive withdrawn RLUIPA claim; no obligation to teach relief options.	Yes; district court properly denied revival of RLUIPA claim.

Hernandez ex rel. Hernandez v. Foster, 657 F.3d 463 (7th Cir. 2011) (framework for clearly established rights with qualified immunity)
Reichle v. Howards, 132 S. Ct. 2088 (2012) (clearly established standard in qualified immunity analysis)
Pearson v. Callahan, 129 S. Ct. 808 (2009) (courts may rule on qualified immunity on a different ground)
Johnson-Bey v. Lane, 863 F.2d 1308 (7th Cir. 1988) (principal authority supporting ban on inmate religious leadership)
Hadi v. Horn, 830 F.2d 779 (7th Cir. 1987) (limits on inmate leadership in religious services)
Kaufman v. Pugh, 733 F.3d 692 (7th Cir. 2013) (RLUIPA proof standards tied to free exercise framework)
Spratt v. Rhode Island Dep’t of Corr., 482 F.3d 34 (1st Cir. 2007) (inmate-led preaching as a point of comparison)
Greene v. Solano Cnty. Jail, 513 F.3d 982 (9th Cir. 2008) (difference between attending vs. leading services)
Maddox v. Love, 655 F.3d 709 (7th Cir. 2011) (allocation of resources among religions not clearly established)
Johnson v. Cypress Hills, 641 F.3d 867 (7th Cir. 2011) (considerations when evaluating withdrawal/withdrawal timing)