Maddox v. Love, 2011 U.S. App. LEXIS 17680

Background

Maddox, an African Hebrew Israelite inmate at Lawrence Correctional Center (2004–2007), attended AHI services until the September 2004 cancellation due to budget cuts.
IDOC terminated the AHI minister’s contract while continuing other faith services, including a Chicago rabbi for Jewish inmates; Chaplain Love supervised AHI and was financially integral to religious programming.
Maddox filed a grievance on October 29, 2004 asserting denial of religious fellowship; the form asked for aBrief summary and Maddox did not name individuals.
The grievance was denied on the merits at all levels (January 12, 2005; Director’s review) with no notice of procedural deficiencies.
District court restructured Maddox’s complaint into four counts (Counts 1–4) and dismissed Counts 2 and 3 for failure to state a claim and Counts 1 and 4 on exhaustion grounds; the Seventh Circuit reversed in part, reinstating Counts 2–3 as plausible, reversing Count 4’s exhaustion dismissal, and affirming Count 1 for failure to exhaust, then remanding for merits on Count 4 and addressing RLUIPA/official-capacity issues.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Counts 2 and 3 state a plausible claim when read in aggregate	Maddox alleges selective treatment and disproportionate budgeting against AHI under First Amendment/Equal Protection/RLUIPA.	Defendants argue no viable claim for disproportionate treatment under settled precedent.	Counts 2 and 3 plausibly state claims.
Whether Maddox exhausted administrative remedies for Count 4 (group worship)	Grievance alerted officials to the denial of religious fellowship and was handled on the merits.	A lack of explicit naming of defendants in the grievance defeats exhaustion.	Counts 4 exhausted; remand for merits on Count 4.
Whether Maddox exhausted administrative remedies for Count 1 (access to religious materials)	Grievance process was followed and addressed on the merits.	Exhaustion requires naming involved individuals; not met for Count 1.	Count 1 properly dismissed for lack of proper exhaustion.
Whether RLUIPA claims are viable against officials in this posture	RLUIPA supports damages against officials independently.	Sovereign immunity bars official-capacity monetary claims; RLUIPA does not support individual-capacity claims.	RLUIPA claims are barred to recover monetary damages and inapplicable against individuals; remaining §1983 claims proceed.
Whether the district court should consider Counts 2–3/Count 4 on the merits after remand	The court should evaluate the totality of the circumstances to determine reasonable opportunities.	Premature to decide merits without full exhaustion/record.	Remand for merits on Counts 2–3 and Count 4; court to address merits and potential qualified immunity on remand.

Key Cases Cited

Cruz v. Beto, 405 U.S. 319 (1972) (religious exercise and allocation of resources in prisons; not required to equalize resources across faiths)
Turner v. Safley, 482 U.S. 78 (1987) (reasonableness balancing for prison restrictions on religious practices)
Al-Alamin v. Gramley, 926 F.2d 680 (7th Cir. 1991) (evenhanded consideration of religious rights; discrimination only to advancing penological goals)
Young v. Lane, 922 F.2d 370 (7th Cir. 1991) (minority religions’ rights must be respected; facilities need not be identical across groups)
Johnson-Bey v. Lane, 863 F.2d 1308 (7th Cir. 1988) (comparing access to worship; differential treatment allowed under penological concerns)
Conyers v. Abitz, 416 F.3d 580 (7th Cir. 2005) (exhaustion doctrine: procedural defects must be explicit or otherwise the grievance serves its function)
Woodford v. Ngo, 548 U.S. 81 (2006) (proper exhaustion requires compliance with prison grievance procedures)
Jones v. Bock, 549 U.S. 199 (2007) (exhaustion is an affirmative defense; proper exhaustion required by prison process)
Curtis v. Timberlake, 436 F.3d 709 (7th Cir. 2005) (early compliance with accepted practices can render grievances effectively exhausted)