Patterson v. Schuyler
- Vince Chhabria
- 3:25-cv-04485
- U.S. District Court · Northern District of California
- 6
In Patterson v. Schuyler, Judge Chhabria found Patterson stated a First Amendment religious-practice claim and ordered service, allowing the case to proceed.
Bryan Damon Patterson’s First Amendment religious-practice claim was allowed to proceed past initial screening, and C. Schuyler was ordered to be served and respond under the schedule in the order.
What happened
Bryan Damon Patterson, a California state prisoner representing himself, sued C. Schuyler under a federal civil-rights law. Patterson alleged that prison officials provided a Passover diet during dates that did not match his religious beliefs.
Patterson claimed this burdened his First Amendment right to practice his religion. He sought damages and unspecified court orders. The court reviewed the complaint under the required prisoner-screening law and concluded that, read broadly, it stated a religious-practice claim.
Judge Vince Chhabria ordered that Schuyler be served and set procedures for responding, motions, discovery, and deadlines. The order allowed the case to proceed but did not decide whether Patterson will ultimately prevail.
The detailed version
- Patterson v. Schuyler · No. 3:25-cv-04485
- Vince Chhabria
- Oct. 9, 2025
Background
Bryan Damon Patterson, a California state prisoner at Salinas Valley State Prison proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983 concerning his religious-practice rights. He also filed a motion to proceed without paying the filing fee, which the court says was granted in a separate order.
Patterson alleged that he receives a kosher diet as a member of the Black House of Yahweh. He alleged that former warden C. Schuyler issued an April 3, 2024 memorandum stating that kosher-diet recipients would receive a Passover diet from April 22 through April 30, 2024. Patterson complained on April 15 that his religious beliefs required him to follow a Passover diet from April 14 through April 21. He alleged that his grievance and appeal were denied and that his First Amendment right to practice his religion was violated. He sought damages and unspecified injunctive relief.
Screening Analysis
Because Patterson is a prisoner seeking relief from a governmental officer, the court screened the complaint under 28 U.S.C. § 1915A. The court explained that screening requires dismissal of claims that are frivolous or malicious, fail to state a claim, or seek money from a defendant immune from that relief. The court also explained that pleadings filed without a lawyer must be read liberally.
For a claim under § 1983, a plaintiff must allege that a federally protected right was violated by a person acting under state authority. The court stated that prisoners retain religious freedom while incarcerated, subject to limitations reasonably related to legitimate prison interests. It concluded that, liberally construed, Patterson stated a First Amendment claim.
Order
The court ordered electronic service on former warden Schuyler through the California Department of Corrections and Rehabilitation’s electronic-service program. It established procedures for waiver or formal service, Schuyler’s answer, potential summary-judgment or other dispositive motions, Patterson’s opposition, and any reply. The order also allowed discovery under the Federal Rules of Civil Procedure and imposed requirements concerning service of Patterson’s communications, address changes, prosecution of the case, and requests for extensions.
This was an order allowing the claim to proceed past initial screening. It did not decide the ultimate merits of Patterson’s religious-practice claim.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.