Vinning-El v. Evans
2011 U.S. App. LEXIS 19053
| 7th Cir. | 2011Background
- Vinning-El, an inmate at Pinckneyville, requested a vegan diet based on Moorish Science Temple beliefs; chaplain Sutton denied incorporating tenets that may conflict with Moorish tenets.
- Vinning-El filed § 1983 and RLUIPA claims against Sutton and Evans; district court granted summary judgment on the RLUIPA claim and denied on the § 1983 claim.
- Sossamon v. Texas held money damages are not available against states under RLUIPA; officials sued in their official capacity are treated as sued against the state.
- Nelson v. Miller held RLUIPA does not authorize relief against public employees, only against governmental bodies receiving federal funds under RLUIPA.
- Evans, the warden, moved for summary judgment; the court held Evans had no personal § 1983 liability due to lack of supervisory involvement and also addressed immunity issues.
- Court reverses Evans on the § 1983 claim and remands for entry of judgment in his favor; Sutton’s immunity determination is vacated and the case is remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Evans has §1983 personal liability | Vinning-El asserts Evans personally caused the denial. | Evans lacks personal involvement; no supervisory liability. | Evans entitled to prevail; district court should grant summary judgment. |
| Whether Sutton's denial violated clearly established rights | Vin ning-El argues sincere vegan belief protected; Sutton violated rights. | Sutton acted within discretionary judgment; immunity may apply if belief sincerity not shown. | Qualified immunity depends on whether Sutton assessed sincerity or merely orthodox tenets; remanded for findings. |
| Whether RLUIPA damages are available against individuals or states | Vinning-El seeks damages under RLUIPA directly against individuals. | RLUIPA does not authorize damages against public employees; only against governmental bodies. | Damages unavailable; RLUIPA claim fails as to individuals and states. |
| Whether the district court erred by applying the wrong constitutional standard (least restrictive means) under a free-exercise claim | Free-exercise claim allowed based on sincere belief; enumerates a violation. | Turner framework controls—restrictions permissible if related to penological objectives; Smith tension unresolved. | Court indicates need to determine sincerity and correct standard; remand for proper analysis of Sutton. |
| Remedy posture after immunity ruling | If Sutton acted on sincere belief, he is not immune. | Sutton may be immune if belief was insincere. | Remand to determine sincerity and apply immunity accordingly; Evans relief affirmed; Sutton remanded. |
Key Cases Cited
- Sossamon v. Texas, 131 S. Ct. 1651 (2011) (damages not available against states under RLUIPA; official-capacity suits treated as against state)
- Nelson v. Miller, 570 F.3d 868 (7th Cir. 2009) (RLUIPA relief not available against public employees)
- Boerne v. Flores, 521 U.S. 507 (1997) (RFRA cannot be applied to states; constitutional limits on enforcement)
- Smith v. Employment Division, 494 U.S. 872 (1990) (free exercise may not require accommodation; Smith vs. Turner tension)
- Turner v. Safley, 482 U.S. 78 (1987) (prison restrictions must be reasonably related to penological interests)
- Frazee v. Illinois Dep't of Employment Security, 489 U.S. 829 (1989) (sincerity of religious belief central to free exercise inquiry)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (clear pleading or immunity standards applicable; personal involvement required for §1983)
- Malley v. Briggs, 475 U.S. 335 (1986) (qualified immunity protects all but plainly incompetent officials)
- Hunter v. Bryant, 502 U.S. 224 (1991) (qualified immunity; court may decide on a theory different from jury)