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Hamza Maldonado and James Hillv.Baker County Sheriff’s Office, et al.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.20-12605
DecidedJanuary 25, 2022
Reporter22 F.4th 1304
JudgesNewsom, Branch, and Lagoa, Circuit Judges
Tags
CivilCivil RightsReligious LibertySection 1983Civil ProcedureDue ProcessReversalRemand
Case Summary

Two Muslim detainees sued a Florida sheriff’s office and employees, alleging they were barred from attending Friday Jummah prayers. They filed in state court, where both received in forma pauperis status; after defendants removed the action and paid the federal filing fee, the district court dismissed Maldonado’s claims under the Prison Litigation Reform Act’s three-strikes rule and Hill’s claims for failure to exhaust grievances. The Eleventh Circuit held that § 1915(g) applies only when a prisoner initiates an action in federal court and seeks in forma pauperis status there; Maldonado did neither. As to Hill, the complaint and response could support his position that no grievance process was available or that he had exhausted it. The district court therefore had to apply the two-step exhaustion test, accept Hill’s account at the first step, and make specific findings if factual disputes remained. The court reversed both dismissals and remanded. It also held Maldonado’s claims were not moot, including because the PLRA’s physical-injury limit did not bar his punitive-damages claim.

Opinion

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