United States Second Circuit

Summary judgment in favor of defendants on plaintiff-inmate's claims that defendants unconstitutionally burdened his religious exercise when they ordered him to provide a urine sample within a three‐hour window while plaintiff fasted in observance of Ramadan, the holy month during which Muslims refrain from ingesting food and drink during daylight hours, is: 1) vacated in part and remanded, where even assuming arguendo that the substantial burden requirement remains a necessary component of a plaintiff’s free exercise claim, defendants' conduct placed such a burden on the plaintiff’s free exercise rights; but 2) affirmed in part, where plaintiff's claim for damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA) is barred, his claims for injunctive relief under RLUIPA and the First Amendment are moot, and he has failed to state a claim for either a denial of due process or First Amendment retaliation.

Appellate Information

• Decided 07/10/2014
• Published 07/10/2014

Judges

• LIVINGSTON

Court

• United States Second Circuit

Counsel