Wilkins v. Lemon
3:15-cv-00514
N.D. Ind.Oct 17, 2016Background
- Plaintiff Daniel E. Wilkens, a pro se prisoner, alleges denial of religious accommodations: Halal-slaughtered meat, Halal prayer oil, and festive foods for Eid observances.
- He sued three IDOC officials: Commissioner Bruce Lemmon (official capacity), David Liebel (Religious Services Director; individual and official capacity), and Mark Sevier. He seeks injunctive relief and monetary damages.
- Grievance response documents attached to the complaint show Liebel denied requests for Halal meals, prayer oil, and festive foods.
- The court screened the complaint under 28 U.S.C. § 1915A and applied First Amendment, RLUIPA, and Equal Protection standards for prison religious accommodation claims.
- The court concluded it is unclear from the record why accommodations were denied but found sufficient allegations to proceed against Lemmon (official capacity/injunctive relief) and Liebel (individual capacity/monetary damages); Sevier and other claims were dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| First Amendment (free exercise) — denial of Halal meat, prayer oil, festive foods | Wilkens: denials prevent him from practicing Islam | Defendants: prison restrictions may be justified by penological interests (security, safety, cost) | Court allowed injunctive relief claim against Commissioner Lemmon (official capacity) and damages claim against Liebel (individual) to proceed |
| RLUIPA — substantial burden on religious exercise | Wilkens: denials impose a substantial burden requiring strict scrutiny | Defendants: burden may be justified by compelling interests and least-restrictive-means concerns | Court allowed RLUIPA injunctive claim to proceed against Lemmon (official capacity); monetary damages unavailable under RLUIPA |
| Equal Protection — disparate treatment compared to other faiths | Wilkens: other groups receive outside-purchased ritual items and special foods; he is treated worse | Defendants: differential treatment may be justified by legitimate penological/economic/security reasons | Court allowed injunctive claim against Lemmon (official) and damages claim against Liebel (individual) to proceed |
| Scope of relief and defendants' liability | Wilkens seeks both injunctive relief and monetary damages from multiple officials | Defendants: some officials may lack authority; RLUIPA bars monetary damages against states/officials | Court limited official-capacity injunctive relief to Lemmon (who has authority) and individual-capacity damages to Liebel; dismissed Sevier and other claims |
Key Cases Cited
- Erickson v. Pardus, 551 U.S. 89 (pro se complaints are to be liberally construed)
- Turner v. Safley, 482 U.S. 78 (prison regulations that impinge on constitutional rights are valid if reasonably related to legitimate penological interests)
- Vinning-El v. Evans, 657 F.3d 591 (prisoners retain free exercise rights)
- Maddox v. Love, 655 F.3d 709 (Prison religious accommodations must be evenhanded and qualitatively comparable)
- Holt v. Hobbs, 135 S. Ct. 853 (RLUIPA imposes strict scrutiny on substantial burdens to inmate religious exercise)
- Sossamon v. Texas, 131 S. Ct. 1651 (RLUIPA does not authorize monetary damages against a State)