Williams v. Diaz

Background

James David Williams, a state prisoner incarcerated at Correctional Training Facility, filed this pro se civil-rights action under 42 U.S.C. § 1983. He alleged that officials limited his ability to order or purchase religious-oil fragrances that he used for daily meditation and prayers. He claimed that officials changed procedures concerning approved religious vendors and special-purchase forms, restricting access to religious oils without notice.

Williams named California Department of Corrections and Rehabilitation Secretary Ralph Diaz and Chaplain Charles Richey, along with Correctional Training Facility officials C. Koenig, B. D. Min, D. Chamberlain, Y. Friedman, and K. Hoffman. He sought declaratory, injunctive, and monetary relief.

Screening standard

Because Williams was a prisoner seeking relief from government officials, the court screened the complaint under 28 U.S.C. § 1915A. That screening requires dismissal of claims that are frivolous, malicious, inadequately pleaded, or seek money from a defendant immune from such relief. The court also applied the rule that a claim under 42 U.S.C. § 1983 requires an alleged violation of a federal right by a person acting under state law.

Claims allowed to proceed

The court held that the complaint stated cognizable claims against Richey, Koenig, and Min for allegedly limiting Williams’s access to religious oils. Those claims arose under:

- the Religious Land Use and Institutionalized Persons Act, which protects a confined person from a substantial burden on religious exercise unless the government satisfies specified requirements; - the First Amendment’s Free Exercise Clause; and - the Fourteenth Amendment.

The court concluded that the complaint adequately linked Richey, Koenig, and Min to the alleged conduct.

Claims dismissed

Williams also claimed that Diaz, Chamberlain, Friedman, and Hoffman were liable for improperly handling his inmate appeal. The court dismissed those claims because prisoners do not have a constitutional right to a prison grievance system, a response to a grievance, or any particular action on a grievance.

The court also dismissed without prejudice Williams’s claim under the Religious Freedom Restoration Act. It explained that the Supreme Court had held the Act unconstitutional as applied to city and state governments. The order’s conclusion stated that Williams’s claims against Diaz, Chamberlain, Friedman, and Hoffman concerning the inmate appeal, together with the Religious Freedom Restoration Act claim, were dismissed without prejudice.

Order and next steps

The court ordered the clerk to send the lawsuit and the order to Richey, Koenig, and Min and to the California Attorney General’s Office. Those defendants were ordered to answer under the Federal Rules of Civil Procedure. The order set a schedule for summary-judgment or other dispositive motions, opposition and reply briefs, and discovery. It also authorized the defendants to depose Williams and other necessary witnesses confined in prison.

Disposition

Judge Yvonne Gonzalez Rogers issued an order of partial dismissal and service. The surviving claims were not resolved on their merits; the order determined only that they were sufficiently pleaded to proceed past preliminary screening.