Washington v. Gonyea, 731 F.3d 143

Background

Washington, a Muslim inmate at Woodbourne Correctional Facility, was disciplined after giving a Quran to a corrections officer; he was found guilty of harassment and received 65 days in special housing plus loss of privileges. The New York Appellate Division later annulled the disposition for lack of substantial evidence.
Washington sued state prison officials (Gonyea, Chaboty, Granger) in federal court under 42 U.S.C. § 2000cc-1 (RLUIPA) alleging a substantial burden on his free exercise rights, and under 42 U.S.C. § 1983 for related First Amendment and due process claims.
The district court dismissed the RLUIPA claim for failure to plead a substantial burden. Washington appealed.
The Second Circuit affirmed dismissal of the RLUIPA claim on independent statutory and constitutional grounds: (1) RLUIPA does not permit money damages against states or state actors in their official capacities (Sossamon v. Texas), and (2) RLUIPA does not create a private cause of action against state officials in their individual capacities because it is Spending Clause legislation aimed at funding recipients, not individual employees.
The court declined to decide whether RLUIPA authorizes individual-capacity suits under the Commerce Clause because Washington did not plead any effect on interstate commerce; injunctive/declaratory relief RLUIPA claims were moot because Washington was no longer in special housing.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RLUIPA authorizes money damages/individual-capacity suits against state officials for burdens on religious exercise	Washington sought relief under RLUIPA against state officers (official and individual capacities) for imposing a substantial burden	Defendants argued sovereign immunity bars monetary damages under RLUIPA and that RLUIPA (as Spending Clause legislation) does not create individual-capacity liability	RLUIPA does not permit money damages against states/state officers in official capacities (Sossamon), and does not create a private cause of action against state officials in their individual capacities under the Spending Clause rationale; claim dismissed
Whether Washington adequately alleged a substantial burden on his religious exercise	Washington alleged discipline for giving a Quran substantially burdened his free exercise	Defendants argued the complaint failed to plead any substantial burden on religious practice	The district court’s conclusion that Washington failed to plead a substantial burden was affirmed on independent statutory/constitutional grounds (individual-capacity barrier); the court also noted the original pleading deficiency but resolved the appeal on the scope-of-RLUIPA grounds
Whether RLUIPA individual-capacity liability can be grounded on the Commerce Clause	Washington invoked RLUIPA generally; no facts pled concerning commerce effects	Defendants noted absence of commerce allegations	Court declined to reach the Commerce Clause question because Washington pled no facts showing an effect on interstate or foreign commerce
Mootness of injunctive/declaratory RLUIPA relief	Washington sought injunctive/declaratory relief tied to special housing status	Defendants argued relief was moot because Washington was no longer in special housing	Court held injunctive/declaratory RLUIPA claims moot and dismissed them

Key Cases Cited

Sossamon v. Texas, 131 S. Ct. 1651 (2011) (States retain sovereign immunity; RLUIPA does not authorize money damages against states or state officers in official capacities)
Nelson v. Miller, 570 F.3d 868 (7th Cir.) (RLUIPA does not authorize individual-capacity suits; Spending Clause limits)
Rendelman v. Rouse, 569 F.3d 182 (4th Cir.) (same: individual officers not liable under RLUIPA absent clear congressional intent)
Smith v. Allen, 502 F.3d 1255 (11th Cir.) (RLUIPA’s remedial reach does not extend to individual-capacity suits under Spending Clause analysis)
Davis ex rel. LaShonda D. v. Monroe County Bd. of Educ., 526 U.S. 629 (1999) (Spending Clause legislation enforcible against the funding recipient, not necessarily individual employees)