126 F.4th 567
7th Cir.2025Background
- Rufus West, an inmate at Green Bay Correctional Institution and practicing Muslim, challenged the Wisconsin Department of Corrections (WDOC) policy prohibiting inmates from leading religious programs, arguing it burdened his religious exercise under RLUIPA.
- West previously settled a lawsuit with WDOC, agreeing that routine Muslim services would not be canceled for lack of external leaders.
- WDOC, after the settlement, continued its policy disallowing inmate-led services, but offered alternatives like staff supervision or live video services when community leaders weren't available.
- West alleges the WDOC's actions violated both RLUIPA and the prior settlement agreement, seeking both injunctive and contractual relief.
- The district court granted summary judgment to WDOC on the RLUIPA claim (finding the policy was the least restrictive means to ensure safety), and granted West summary judgment on liability for breach of contract but relinquished jurisdiction on the remedy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does WDOC's prohibition of inmate-led religious programs violate RLUIPA? | Prohibiting inmate-led services substantially burdens West’s religious practice without being the least restrictive means. | Policy is necessary for prison security; alternatives are provided and securing enough staff or volunteers isn't feasible. | Policy is the least restrictive means to ensure safety and security; WDOC prevails. |
| Whether hiring/changing recruitment of leaders is a feasible alternative under RLUIPA | WDOC should hire or recruit more external religious leaders to avoid cancellations. | Cost and recruitment burdens are prohibitive; recruiting efforts already exist. | Court agrees with WDOC; hiring/recruitment burdens are not required under RLUIPA. |
| Does WDOC’s cancellation of programs breach the prior settlement agreement? | Cancellation of six Talim sessions violated explicit settlement terms. | Not directly disputed in the appeal; focused on retaining/remedy jurisdiction. | District court correctly found WDOC liable for breach of contract on liability. |
| May the district court relinquish supplemental jurisdiction over only the remedy, not the whole claim? | Allowed to dismiss injunctive relief, retain jurisdiction on liability issue. | Should relinquish the entire claim—not just the remedy—under 28 U.S.C. § 1367(c). | Court: Must relinquish entire state law claim, not just the remedy; judgment vacated and remanded. |
Key Cases Cited
- Cutter v. Wilkinson, 544 U.S. 709 (2005) (courts must give deference to prison officials’ expertise under RLUIPA, especially regarding security)
- Holt v. Hobbs, 574 U.S. 352 (2015) (unquestioning deference to prison policies not required under RLUIPA)
- Koger v. Bryan, 523 F.3d 789 (7th Cir. 2008) (explains burden shifting for RLUIPA claims in the Seventh Circuit)
- West v. Grams, 607 F. App’x 561 (7th Cir. 2015) (prior appeal related to West’s RLUIPA claims; provides procedural background)
- St. Augustine School v. Underly, 78 F.4th 349 (7th Cir. 2023) (defines "claim" for supplemental jurisdiction purposes)