Wood v. Yordy

The Religious Land Use and Institutionalized Persons Act does not authorize suits against a person in anything other than an official or governmental capacity.

Lance Wood is serving a life sentence in Idaho. He considers himself to be an extremely religious person and is engaged in many activities in the prison chapel at the Idaho State Correctional Institution (“ISCI”). Wood’s chapel access was curtailed when the warden determined that he had been carrying on romantic relationships with prison guards. Wood filed a complaint against the prison officials in their individual capacities. The claim was brought under the Religious Land Use and Institutionalized Persons Act (“RLUIPA”) alleging they had imposed an unwarranted burden on his exercise of religion. Wood also claimed that his First Amendment rights were violated when the defendants acted in retaliation for an earlier suit that he prevailed on during his appeal. The district court was asked whether Wood could seek damages against prison officials in their individual capacities. The district court answered that question in the negative and the Ninth Circuit agreed. The panel held that RLUIPA’s reach is limited to prohibiting a “government” from burdening religious exercise in correctional institutions. The Act was enacted via Congress’ constitutional powers under the Spending Clause. Since the individual defendants are not recipients of any federal funds they cannot be subjected to individual suits. Wood’s suit against the defendants in their individual capacities seeks to hold them liable for their personal conduct, which is not the purpose of RLUIPA. As to the second issue the district court and panel agree that there is insufficient evidence to show that the officials knew of Wood’s earlier suit and there is little evidence to show that any of their actions were in retaliation to that suit. AFFIRMED.