Religious Land Use and Institutionalized Persons Act

Listen to this article

7^th Circuit Court of Appeals

Case Name: Thomas Walker v. John Baldwin

Case No.: 22-2342

Officials: Flaum, Rovner, and St. Eve, Circuit Judges

Focus: Religious Land Use and Institutionalized Persons Act

Officer Brinkmeier at Dixon Correctional Center informed inmate Walker that prison policy prohibited inmates from having “unsearchable” hairstyles, specifically mentioning dreadlocks. Walker, who identified as a Rastafarian, explained to Brinkmeier that his faith required him not to cut his hair. Despite this, Brinkmeier returned with another officer and reiterated the order for Walker to cut his dreadlocks. When Walker refused, the officers disciplined him by placing him in segregated housing for several days. Walker submitted an emergency grievance, but it was denied without any explanation. He was then warned that if he did not comply, a tactical unit would forcibly cut his dreadlocks. Consequently, Walker allowed the prison barber to shave his hair, but he regrew his dreadlocks and kept them for the next three years. During his time at the prison, officers frequently ran their gloved hands through his dreadlocks during security checks. When Walker was eventually released from Dixon, his dreadlocks had grown to roughly the same length as they were when he first entered the prison.

In response to these events, Walker filed a lawsuit alleging violations of his First Amendment rights and the Religious Land Use and Institutionalized Persons Act (RLUIPA), specifically 42 U.S.C. 2000cc-1. The district court acknowledged that, based on Circuit precedent, Walker could not seek monetary damages against individual defendants under RLUIPA. The only available relief under RLUIPA, which is injunctive relief, was deemed moot as Walker had already been released from prison. Additionally, the court granted the defendants summary judgment on Walker’s First Amendment claim, citing qualified immunity. An appeal to the Seventh Circuit was subsequently dismissed, as the court found that Walker had abandoned his RLUIPA damages claim.

Affirmed.

Decided 07/26/23

Full Text