Revels v. Santa Rita Jail

Background

Tyler Revels brought a civil-rights action under 42 U.S.C. § 1983 against Santa Rita County Jail officials Tichia Holly and Gary Dean White. He alleged that they violated his First Amendment right to freely practice his religion by denying or ending video visits because he wore a kufi, a religious head covering. The court had previously found that this allegation stated a legally sufficient claim. After the case was reopened, the defendants moved for summary judgment.

Jail procedures and events

Santa Rita Jail generally prohibited headwear for security reasons but allowed religious headwear if both the jail chaplain and jail staff approved it. Staff recorded those approvals in the jail’s management system, known as ATIMS. Holly relied on ATIMS when monitoring video visits. If a person wore headwear that appeared unauthorized, Holly’s normal practice was to issue a warning and allow the person to correct the problem or provide proof of approval. If the person continued wearing the headwear without proof, Holly could end the visit and temporarily suspend video-visit privileges. Audio-only calls remained available through telephones in the housing pods.

The chaplain approved Revels’s kufi on June 5, 2023, but White did not enter the approval into ATIMS. On June 30 and July 2, 4, and 5, Revels’s video visits were cut short because officials relied on ATIMS and concluded that his kufi was unauthorized. Holly monitored the July 2 and July 4 visits but was not working and had no involvement in the June 30 or July 5 incidents. On July 5, White learned that the approval was missing from ATIMS and entered it into the system that day.

White stated that the failure to update ATIMS was accidental and that he did not intend to discriminate against or punish Revels for his religious beliefs. Revels alleged that White acted intentionally, partly in retaliation for grievances, and that Holly knew the records were inaccurate and ended the visits because of Revels’s religion. The court characterized Revels’s allegations about their intent as speculative and conclusory.

Legal standard

Summary judgment is appropriate when the evidence shows no genuine dispute about a fact that could affect the result and the moving party is entitled to judgment as a matter of law. The court must view genuinely disputed evidence in favor of the party opposing the motion, but the opposing party must provide evidence sufficient for a reasonable jury to find in that party’s favor.

For a First Amendment religious-exercise claim by a person detained before trial, the alleged restriction must substantially burden a sincerely held religious belief, and the restriction must be unreasonable rather than rationally related to legitimate government interests. A substantial burden is more than an inconvenience; it must tend to coerce a person to act against religious beliefs or place substantial pressure on the person to change religious behavior.

Court’s analysis and ruling

The court granted summary judgment in favor of the defendants. It held that Revels had not shown a triable issue of fact on whether the defendants substantially burdened his religious practice. The court emphasized that Revels missed four video visits over a six-day period, that Holly was not involved in two of the cancellations, and that Revels could use audio-only calls. It concluded that the video-visit cancellations were relatively short-term and sporadic intrusions that inconvenienced Revels but did not substantially pressure him to violate his beliefs.

The court therefore granted the defendants’ motion for summary judgment, entered judgment in favor of the defendants and against Revels, terminated pending motions as moot, and closed the case.