Lance Wood v. Keith Yordy, 2014 U.S. App. LEXIS 10256

Background

Plaintiff Lance Wood, an Idaho state prisoner, alleged prison officials restricted his chapel access after discovering he used chapel contacts to pursue romantic relationships with officers.
Wood sued under RLUIPA for damages against individual prison officials (Yordy, Nelson) and brought § 1983 retaliation claims (including against Ludlow) based on an earlier successful suit (Wood v. Beauclair).
District court granted summary judgment for defendants on all claims; Wood appealed.
Central factual disputes: restrictions on chapel access, alleged harassment and a false contraband report by Ludlow, and statements by officials arguably referencing prior litigation.
The court found insufficient evidence of retaliatory motive and addressed whether RLUIPA permits individual-capacity damages suits when individual defendants do not receive federal funds.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RLUIPA authorizes damages against state prison officials in their individual capacities	RLUIPA allows individuals to obtain "appropriate relief" against a "government," and suits against officers individually are permissible	RLUIPA was enacted under the Spending Clause; individual officers are not recipients of federal funds and thus cannot be bound by spending-conditions that would permit individual damages suits	RLUIPA does not authorize individual-capacity damages suits against officials who are not recipients of federal funds; affirming summary judgment for defendants
Whether Sabri v. United States undermines Spending-Clause limits on individual liability under RLUIPA	Sabri shows liability can reach non‑recipients of federal funds because it protects entities receiving federal funds	Sabri concerned criminal bribery protecting the financial integrity of the fund recipient; it does not authorize civil damages against private individuals for personal conduct	Sabri does not change the conclusion; it does not authorize individual-capacity RLUIPA damages suits
Whether Centro Familiar v. Yuma supports individual-capacity RLUIPA liability	Yuma suggests entities without state sovereign immunity can be liable under RLUIPA, implying individuals could be liable too	Yuma involved a municipality and a different RLUIPA provision; facts involved federal funding and did not reach individual liability absent federal funds	Yuma does not support individual-capacity damages against non‑funded officials under RLUIPA
Whether there is a triable issue on Wood’s First Amendment retaliation claim	Statements and a memo by officials, plus alleged harassment, show retaliatory motive tied to prior suit	The record lacks evidence linking officials’ actions or knowledge to the prior suit; speculation is insufficient	Summary judgment affirmed: insufficient evidence of retaliatory motive

Key Cases Cited

Pennhurst State School & Hospital v. Halderman, 451 U.S. 1 (Spending Clause conditions function like a contract)
City of Boerne v. Flores, 521 U.S. 507 (limits on Congress’s Fourteenth Amendment enforcement power)
Sossamon v. Texas, 131 S. Ct. 1651 (RLUIPA enacted under Spending and Commerce Clauses; "appropriate relief" and sovereign immunity limits)
Sabri v. United States, 541 U.S. 600 (criminal liability under Spending Clause can reach nonrecipients to protect fund integrity)
Nelson v. Miller, 570 F.3d 868 (7th Cir. holding Spending-Clause legislation cannot subject non‑funded state officers to individual suits)
Stewart v. Beach, 701 F.3d 1322 (10th Cir. rejecting individual‑capacity RLUIPA damages suits)
Sharp v. Johnson, 669 F.3d 144 (3d Cir. same holding on individual capacity suits under RLUIPA)
Rendelman v. Rouse, 569 F.3d 182 (4th Cir. rejecting individual damages suits, focusing on notice and Spending Clause limits)
Kentucky v. Graham, 473 U.S. 159 (distinction between official‑capacity and individual‑capacity suits)
Wood v. Beauclair, 692 F.3d 1041 (9th Cir. prior appeal in related due process claim)