Robert Williams, Sr. v. State of California
2014 U.S. App. LEXIS 16061
9th Cir.2014Background
- Native residential care facilities and their employees sued the State of California and a regional center under 42 U.S.C. §1983 for alleged First Amendment violations related to being forced to provide direct staff support to a developmentally disabled client attending Jehovah's Witness services.
- California's Lanterman Developmental Disabilities Services Act (and related regulations) governs services for developmentally disabled persons and includes rights to religious freedom and attendance, participation, or refusal of worship.
- The district court dismissed the FAC, finding no First Amendment violation and determining certain defendants lacked sufficient personal allegations; it denied leave to amend due to futility.
- Plaintiffs appealed the dismissal, arguing the Lanterman Act and regulations were misinterpreted and violated free exercise and establishment principles, among others.
- The Ninth Circuit affirmed, adopting the district court’s reasoning and disposition, and held the claims failed as a matter of law on the asserted theories.
- Appendix A contains the district court disposition under review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Lanterman Act regulations violate the First Amendment. | Plaintiffs contend the Act’s interpretation coerces religious conduct. | Defendants argue regulations are neutral, generally applicable, and constitutional. | Regulations are neutral, generally applicable, and do not violate the First Amendment. |
| Whether plaintiffs stated a Free Exercise Clause claim. | Plaintiffs claim the regulations burden their religious practice by requiring presence at services. | The general applicability of neutral regulations does not infringe free exercise. | No Free Exercise violation; regulations do not target religion and are neutral. |
| Whether the Establishment Clause was violated. | Regulations improperly promote religion by requiring attendance or accompaniment. | Regulations have secular purpose and do not advance or inhibit religion. | Establishment Clause not violated; Lemon test abnormalities not satisfied. |
| Whether plaintiffs stated a retaliation claim under the First Amendment. | Citing rights allegedly caused defendants to sanction or cut referrals in retaliation. | Sanctions were mandatory under Lanterman Act regulations; not retaliatory. | No plausible retaliation claim; allegations insufficient to show a causal link. |
| Whether plaintiffs properly asserted a Title VII claim. | Plaintiffs claimed Title VII issues arising from staff attendance requirements. | No employment relationship shown; failure to exhaust administrative remedies. | No Title VII claim; amendment would be futile. |
Key Cases Cited
- Robinson v. Fair Emp't & Hous. Comm'n, 2 Cal.4th 226 (Cal. 1992) (statutory construction guidance in regulatory interpretation)
- Church of Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (U.S. 1993) (neutral and generally applicable standards—Lemon test framework)
- Everson v. Bd. of Educ., 330 U.S. 1 (U.S. 1947) ( Establishment Clause framework and neutrality principle)
- Mayweathers v. Newland, 314 F.3d 1062 (9th Cir. 2002) (accommodating religious practices under neutral laws permitted)
- Stormans, Inc. v. Selecky, 586 F.3d 1109 (9th Cir. 2009) (neutral, generally applicable laws; balancing free exercise)