Riehl v. Martin, 9:13-cv-00439

Plaintiff Charles Jacob Riehl, an incarcerated self-identified Orthodox Jew, sued defendants (Donna Martin, Howard Matasar, and Harold Graham) under RLUIPA and 42 U.S.C. § 1983 for alleged Free Exercise violations stemming from being served chametz (forbidden leavened foods) at a Passover seder in April 2012.
Defendants moved for summary judgment in lieu of answering; Riehl responded and added new factual allegations in opposition and sought to amend dates in his complaint.
Magistrate Judge Therèse Wiley Dancks issued an R&R recommending dismissal of all claims except Riehl’s § 1983 Free Exercise claim against Martin and Matasar, and recommended leave to amend.
Riehl filed objections that largely rehashed earlier arguments and contested portions of declarations, but did not identify specific errors in the R&R.
District Judge Gary L. Sharpe reviewed the R&R for clear error (because objections were non-specific), found no clear error, adopted the R&R in full, and entered partial summary judgment accordingly.
The court granted summary judgment for Graham on all claims, granted RLUIPA relief to defendants Martin and Matasar (i.e., dismissed RLUIPA claim), denied injunctive relief requests, and left only a § 1983 Free Exercise claim against Martin and Matasar; Riehl was given leave to file a single, integrated amended complaint with sufficient factual detail about defendants’ roles.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RLUIPA claim survives summary judgment	Riehl contends the Passover meal violated RLUIPA protections by containing chametz	Defendants argue no RLUIPA violation and moved for summary judgment	RLUIPA claim dismissed as to Martin and Matasar (summary judgment granted)
Whether First Amendment § 1983 Free Exercise claim survives	Riehl alleges deprivation of free exercise because he was served forbidden food	Defendants argue insufficient basis for Free Exercise claim	Free Exercise § 1983 claim remains against Martin and Matasar (survives summary judgment)
Whether claims against Graham should proceed	Riehl included Graham as a defendant for the incident	Defendants argued no actionable involvement by Graham	All claims against Graham dismissed (summary judgment granted)
Whether Riehl’s objections require de novo review of the R&R	Riehl objected generally and reasserted prior factual assertions	Defendants urged deference due to lack of specific objections	Court reviewed for clear error and adopted the R&R; objections deemed non-specific and insufficient

(No officially reported cases with reporter citations were relied upon in the opinion.)