Anthony Davilav.Robin Gladden, et al.
Anthony Davila, a federal prisoner and Santeria priest, alleged that prison officials violated constitutional and statutory protections for his religious exercise by refusing to let his goddaughter send him beads and shells infused with the religious force Ache. The district court dismissed RFRA damages claims, granted summary judgment against Davila on his First Amendment claims and RFRA injunction claim, and rejected the remaining relief. The Eleventh Circuit held that Davila had shown a substantial burden on a sincerely held religious practice at the summary-judgment stage, while the prison had not produced sufficient evidence that the ban furthered a compelling interest or was the least restrictive means. The court therefore reversed summary judgment on the RFRA claim for injunctive relief and remanded that claim for further proceedings. It held that RFRA did not clearly waive federal sovereign immunity for official-capacity damages and that the officials would have qualified immunity even if individual-capacity damages were authorized. The court affirmed summary judgment on the First Amendment claims because the prison restriction was reasonably related to legitimate security and resource interests under Turner v. Safley, and affirmed the remainder of the district court’s rulings.
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