Pfeil v. Lampert
603 F. App'x 665
| 10th Cir. | 2015Background
- Pfeil, a Wyoming state prisoner, sued WDOC Director Lampert and WHF Warden Pacheco in their official and individual capacities under RLUIPA and the Free Exercise Clause, later adding ADA and retaliation claims.
- He alleged two main deprivations: (i) banning hardbound books, depriving him of large-print Bibles and a commentary; (ii) barring a Eucharistic Minister entry due to an up-to-date application requirement.
- The district court granted summary judgment for defendants on all claims, and Pfeil appealed.
- The panel held RLUIPA claims moot because Pfeil was released from WDOC custody prior to or during review, remanding those claims for dismissal.
- On the remaining claims, the court upheld the district court’s analysis that the policies served legitimate penological interests and were reasonably related to those goals, and that Pfeil failed to exhaust an ADA claim and to establish retaliation evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RLUIPA mootness after release | Pfeil argues RLUIPA remains capable of providing relief. | Defendants contend release moots the RLUIPA claims since they seek only equitable relief. | RLUIPA claims moot; affirmed dismissal and remanded for dismissal. |
| Volunteer minister entry policy and Free Exercise | Policy burdens Pfeil's free exercise by restricting access to services due to outdated information. | Policy reasonably relates to penological interests and provides minimal burdens with alternatives. | Policy upheld as reasonable under O’Lone/Turner framework; no constitutional violation. |
| Hardbound book prohibition and Free Exercise | Prohibition deprives Pfeil of essential religious texts in large print fonts. | Policy serves security and operational interests; alternatives exist (softboundbooks, library). | Policy reasonable; no Free Exercise violation. |
| ADA exhaustion and duty to accommodate | ADA claim should proceed; Pfeil sought accommodation for vision impairment. | ADA claim not exhausted in grievances and Pfeil did not plead a disability in those grievances. | ADA claim not exhausted; affirm denial on this basis. |
| Retaliation claims | Defendants retaliated against Pfeil for filing suit (e.g., transfers). | Lack of personal participation and insufficient evidence refute retaliation. | District court's dismissal affirmed; no reversible error found. |
Key Cases Cited
- Sossamon v. Texas, 131 S. Ct. 1651 (2011) (RLUIPA injunctive relief only; Eleventh Amendment immunity)
- Kay v. Bemis, 500 F.3d 1214 (10th Cir. 2007) (burden framework for evaluating religious accommodations in prison)
- Abdulhaseeb v. Calbone, 600 F.3d 1301 (10th Cir. 2010) (no subsidy for religious materials; accommodations limited)
- Cutter v. Wilkinson, 544 U.S. 709 (Supreme Court 2005) (no subsidization of inmate devotional accessories; free exercise standards)