United States Third Circuit

In a prisoner's suit claiming that two prison facilities unlawfully denied his request to accommodate his particular religious group, a magistrate judge's denial of the claims is affirmed, where: 1) the Religious Land Use and Institutionalized Persons Act of 2000 does not permit actions against state officials in their individual capacities; and 2) the magistrate judge did not err in concluding that the defendants were protected by qualified immunity as to violations of the First Amendment, although she did err in placing the burden on the plaintiff to demonstrate that the denial of his request had no rational connection to any legitimate penological interest.

Appellate Information

• Decided 02/09/2012
• Published 02/09/2012

Judges

• Smith

Court

• United States Third Circuit

Counsel

• For Appellant:
  
• Anderson T. Bailey, Kemal A. Mericli