Sharp v. Johnson
2012 U.S. App. LEXIS 2560
| 3rd Cir. | 2012Background
- Sharp, an inmate, challenged two Pennsylvania DOC facilities for denying his Habashi Sunni Muslim group accommodations.
- He claimed the DC-ADM 819/DC-52 process and related procedures failed to recognize his Habashi sect distinct from Sunni groups at SCI-Pittsburgh and SCI-Greene.
- At SCI-Pittsburgh, Sharp sought separate Habashi Jumah and Taleem services; officials indicated he should file proper DC-52 forms and not group-requested accommodations.
- Sharp was placed in administrative custody in 1999 for alleged unrest related to organizing a Habashi group; PRC considered a behavioral modification contract but did not restrict religious practice.
- After transfer to SCI-Greene, Sharp submitted a DC-52 request; central office denied it, noting he could practice privately or attend existing Islamic services.
- Proceedings culminated in bench trials; the magistrate judge granted summary judgment in favor of defendants on both the First Amendment and RLUIPA claims, which the Third Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RLUIPA individual-capacity liability | RLUIPA allows actions against state officials individually. | RLUIPA damages liability does not extend to individual state actors. | RLUIPA does not permit damages actions against individuals. |
| First Turner factor burden allocation | Prison officials must negate all penological interests; Sharp bears ultimate burden. | Prison officials must show a rational connection to a legitimate penological interest. | Magistrate erred in placing the First Turner Factor burden on Sharp; but qualified immunity defeats relief on the merits. |
| Qualified immunity | Defendants violated clearly established rights by denying Habashi accommodation. | Officials reasonably believed their conduct complied with the law. | Defendants were entitled to qualified immunity. |
| Existence of a protected right to Habashi-specific services | Inmates have a right to congregate religious services where a substantial group exists. | No entitlement to separate Habashi services when Sunni services are available. | No clearly established right to separate Habashi services; availability of existing services suffices. |
Key Cases Cited
- Waterman v. Farmer, 183 F.3d 208 (3d Cir.1999) (inmate rights limited by Turner; not all rights lost)
- Turner v. Safley, 482 U.S. 78 (Supreme Court 1987) (prison regulations must be reasonably related to penological interests)
- Overton v. Bazzetta, 539 U.S. 126 (Supreme Court 2003) (burden of challenge to prison regulation on inmate)
- Jones v. Brown, 461 F.3d 353 (3d Cir.2006) (burden for First Turner Factor rests with inmate vs. officials)
- Beard v. Banks, 548 U.S. 521 (Supreme Court 2006) (prisoner bears burden to show regulations fail to meet penological interests)
- Sossamon v. Texas, 131 S. Ct. 1651 (Supreme Court 2011) (RLUIPA and sovereign immunity; funding-spending clause considerations)
- Pennhurst State School & Hosp. v. Halderman, 451 U.S. 1 (Supreme Court 1981) (unambiguous spending-power conditions required for accepting federal funds)
- Nelson v. Miller, 570 F.3d 868 (7th Cir.2009) (RLUIPA individual-capacity liability and spending power limits)
- Rendelman v. Rouse, 569 F.3d 182 (4th Cir.2009) (RLUIPA scope and government-entity liability)
- Sossamon v. Lone Star State of Texas, 560 F.3d 316 (5th Cir.2009) (RLUIPA damages claims and sovereign-immunity considerations)