United States First Circuit

In a prisoner's challenge under the Religious Land Use and Institutionalized Persons Act (RLUIPA) to his transfer to another prison, based on its lack of outside clergy, volunteer visitors, and practicing co-religionists, the district court's denial of the plaintiff's motion for a preliminary injunction is affirmed, where the plaintiff's disadvantages in the new prison depended importantly on proximate actions and decisions not attributable to the government and were too attenuated from the transfer decision to be considered government imposed burdens under RLUIPA.

Appellate Information

• Decided 03/29/2012
• Published 03/29/2012

Judges

• Boudin

Court

• United States First Circuit

Counsel

• For Appellant:
  
• Michael J. Sheehan, Laura E. B. Lombardi