Teddy Davis v. Billy Pierce
826 F.3d 258
| 5th Cir. | 2016Background
- Plaintiffs Teddy Davis and Robbie Goodman are Native American inmates at TDCJ’s McConnell Unit (both low-security/G2) who sued under RLUIPA and the First Amendment challenging TDCJ policies on: smoking prayer pipes at ceremonies, wearing medicine bags, and growing long hair or a kouplock.
- Plaintiffs sought declaratory and injunctive relief under RLUIPA and damages under the First Amendment; most claims were resolved on cross-motions for summary judgment and appeal.
- The district court found Plaintiffs sincere and that TDCJ policies substantially burdened religious exercise, but concluded TDCJ satisfies RLUIPA’s compelling-interest/least-restrictive-means test and granted summary judgment for Defendants; qualified immunity was also applied to the First Amendment damages claim.
- This panel AFFIRMED the district court as to the First Amendment claim, the medicine-bag RLUIPA claim, and the pipe-ceremony RLUIPA claim, finding those regulations justified and/or previously upheld by this Court.
- The court VACATED and REMANDED the grooming-policy (kouplock/long-hair) RLUIPA claim because the district court’s summary-judgment ruling did not clearly consider Plaintiffs’ proffered summary-judgment evidence (including prior expert testimony) nor evaluate the ban as applied to Plaintiffs’ particular low-security circumstances per Holt v. Hobbs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| First Amendment damages claim (qualified immunity) | Prison rules violated free-exercise rights; qualified immunity overcome | Regulations reasonably related to penological interests; thus no clearly established violation | Affirmed: qualified immunity properly applied; no First Amendment violation shown |
| Medicine-bag (RLUIPA) | Ban on wearing medicine bag outside cell/subscribed times substantially burdens religion | Policy furthers security and cost interests; no less-restrictive alternative | Affirmed: defendants carried burden; Plaintiffs did not rebut evidence of least-restrictive means |
| Prayer-pipe smoking at ceremonies (RLUIPA) | Plaintiffs must be allowed to smoke personal pipes (health concern with communal pipe) | TDCJ policy permits only chaplain to smoke; health/security/logistics justify ban; Court previously rejected personal-pipe accommodation | Affirmed: consistent with Chance; ban is least-restrictive means given prison interests |
| Grooming policy — kouplock/long hair (RLUIPA, as-applied) | Total ban is not least-restrictive as applied to these low-risk inmates; offered prior expert testimony showing minimal security risk | TDCJ asserts contraband/identification/security risks justify ban across population | Vacated and remanded: district court did not clearly consider Plaintiffs’ summary-judgment evidence or evaluate the policy against Plaintiffs’ individual characteristics (Holt requires person-specific analysis) |
Key Cases Cited
- Tolan v. Cotton, 134 S. Ct. 1861 (2014) (nonmovant’s evidence must be believed and inferences drawn in their favor on summary judgment)
- Turner v. Safley, 482 U.S. 78 (1987) (prison regulations valid if reasonably related to legitimate penological interests)
- Holt v. Hobbs, 135 S. Ct. 853 (2015) (RLUIPA requires evaluation of compelling-interest/least-restrictive-means as applied to the particular claimant)
- Chance v. Texas Dep’t of Criminal Justice, 730 F.3d 404 (5th Cir. 2013) (upholding TDCJ policy limiting pipe-smoking to ceremony leader under RLUIPA)
- Adkins v. Kaspar, 393 F.3d 559 (5th Cir. 2004) (framework assigning burdens under RLUIPA)
- Cutter v. Wilkinson, 544 U.S. 709 (2005) (courts must give due deference to prison administrators while enforcing RLUIPA)