Henderson v. Thomas
- Edward Davila
- 5:22-cv-02166
- U.S. District Court · Northern District of California
- 6
In Henderson v. Thomas, Judge Davila dismissed RLUIPA damages and equal protection claims with prejudice, while allowing First Amendment and due process claims to proceed.
JohnDell Henderson’s Religious Land Use and Institutionalized Persons Act damages and equal protection claims were dismissed with prejudice. His First Amendment and due process claims against the listed Salinas Valley State Prison defendants remain pending.
What happened
In Henderson v. Thomas, JohnDell Henderson, a state inmate proceeding without a lawyer, sued officers at Salinas Valley State Prison under the federal civil-rights law. He alleged that officials denied Muslim inmates religious meals and opportunities to gather for prayer, and asserted First Amendment, due process, equal protection, and Religious Land Use and Institutionalized Persons Act claims.
The court had previously found that the First Amendment and due process claims could proceed, dismissed the claim for damages under the Religious Land Use and Institutionalized Persons Act, and gave Henderson time to amend his equal protection claim. Henderson did not file an amended complaint.
Judge Edward J. Davila dismissed the Religious Land Use and Institutionalized Persons Act damages claim and the equal protection claim with prejudice for failure to state a claim. The First Amendment claims concerning assembly and religious practice, and the due process claim concerning denial of religious gatherings, will proceed; the defendants must be served and file a summary-judgment or other case-ending motion.
The detailed version
- Henderson v. Thomas · No. 5:22-cv-02166
- Edward Davila
- Nov. 22, 2022
Background
JohnDell Henderson, a state inmate proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983 against officers at Salinas Valley State Prison. He alleged that officials violated his rights by denying Muslim inmates religious meals and limiting their opportunities to assemble for prayer and religious services. He sought a court declaration and damages.
Henderson alleged violations of the First Amendment right to peaceably assemble and the free exercise of religion, the Religious Land Use and Institutionalized Persons Act, due process, and equal protection. The court’s earlier screening order found the First Amendment and due process allegations sufficient to proceed. It dismissed the claim for damages under the Religious Land Use and Institutionalized Persons Act and dismissed the equal protection claim with permission to amend.
Screening and Claim Dispositions
Under the prisoner-screening statute, 28 U.S.C. § 1915A, the court must identify claims that are frivolous, malicious, inadequately pleaded, or seek monetary relief from an immune defendant. The court must read filings from people without lawyers liberally, but the complaint still must state a legally sufficient claim.
Because Henderson did not file an amended complaint within the time provided, the court dismissed the equal protection claim with prejudice for failure to state a claim. The court’s conclusion also dismissed with prejudice the Religious Land Use and Institutionalized Persons Act claim seeking damages against the named defendants in their individual capacities.
The action proceeds on the First Amendment claims involving the denial of peaceful assembly and the free exercise of religion, as well as the due process claim based on the alleged arbitrary denial of religious gatherings.
Service and Next Steps Ordered
The court ordered service on the listed Salinas Valley State Prison defendants, including Captain Michael Thomas, Lieutenant Herman Clavijo, Sergeant Pedro Soto, Captain Lenard M. Pennisi, Jr., Lieutenant Sandeep Bangar, Sergeant Christian Cole, Sergeant Hector Lomeli, Sergeant Elisa Macay, Lieutenant Robert Poodry, Lieutenant Christy Tange, Alma Tamayo, Tammie Frost, and Tina Lopez.
The defendants must file a summary-judgment motion or another dispositive motion concerning the claims allowed to proceed no later than 91 days after the order was filed. Henderson must respond within 28 days after such a motion is filed, and the defendants must reply within 14 days after Henderson’s response. The court also authorized discovery under the Federal Rules of Civil Procedure and provided instructions concerning service, communications, deadlines, and prosecution of the case.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.