Bryant v. Miller

Background

Thomas Bryant, an incarcerated person at Sing Sing Correctional Facility who proceeded without a lawyer, sued Superintendent Michael Capra and Ms. Hickson under 42 U.S.C. § 1983 and the Religious Land Use and Institutionalized Persons Act. Bryant alleged that Hickson told him he could not keep his floor-length dreadlocks secured during recreation unless he used a religious hair covering. Bryant described himself as nonreligious and alleged that, because he would not use religious protective gear, he stopped going to the prison yard and suffered physical and mental-health consequences.

Bryant asserted claims under the First Amendment’s Free Exercise and Establishment Clauses, the Equal Protection Clause, and the Eighth Amendment, along with claims under the Religious Land Use and Institutionalized Persons Act. He sought damages and an order requiring different treatment. Defendants moved to dismiss the second amended complaint. The court treated that complaint as the operative pleading and found the earlier motion to dismiss moot.

Court’s analysis

The court applied the standard for a Rule 12(b)(6) motion to dismiss, asking whether the complaint alleged enough facts to make each claim legally plausible. It accepted the pleaded facts as true and interpreted Bryant’s self-represented complaint liberally, but explained that this did not excuse compliance with substantive and procedural law.

Religious-protection claims. The court held that the Religious Land Use and Institutionalized Persons Act does not allow monetary-damages claims against state officers in either their official or individual capacities, although it can allow injunctive relief. Bryant’s claim for damages under that law was therefore invalid. As to injunctive relief, the court applied the same initial question used for his First Amendment claim: whether the challenged conduct substantially burdened a sincerely held religious belief.

First Amendment Free Exercise claim. The court recognized that the First Amendment can protect a person’s choice not to follow a religion. But it held that Bryant did not plausibly allege a substantial burden on that belief. Capra’s grievance decision stated that inmates with below-shoulder-length dreadlocks could use a barrette, rubber band, or another approved fastening device. The court found that Directive 4914 did not require a religious head covering; it required dreadlocks to be tied back and separately allowed dreadlocks to be worn in an approved religious covering. Bryant did not allege that he tried to obtain a secular fastening device or secular covering, that officials prevented him from doing so, or that officials later told him only religious coverings were allowed.

The court also dismissed any Free Exercise claim based solely on Hickson’s alleged one-time misstatement of the policy. Bryant did not allege facts showing that the statement placed substantial pressure on him to violate his beliefs, and an alleged violation of a prison directive by itself does not create a federal civil-rights claim.

Establishment Clause claim. The court understood Bryant’s Establishment Clause claim to allege that the policy improperly established a state religion. It rejected that claim because the directive accommodated religions that may require dreadlocks or religious head coverings without favoring a particular religion or barring nonreligious inmates from using a head covering. The directive also allowed religious and nonreligious inmates to use approved fastening devices.

Equal Protection claim. The court held that Bryant’s Equal Protection claim was derivative of and duplicative of his Free Exercise claim. Bryant did not identify a protected class, a similarly situated comparison inmate, or facts suggesting intentional or purposeful discrimination. At most, the allegations suggested that defendants misread or misapplied the directive, which was insufficient to support an Equal Protection claim.

Eighth Amendment claims. The court analyzed Bryant’s allegations as claims for deliberate indifference to medical needs and unconstitutional conditions of confinement. It held that Bryant did not plausibly allege a sufficiently serious medical deprivation. The court also noted that the complaint did not clearly allege that Hickson ordered him out of the yard or that either defendant actually barred him from exercising. Even assuming a restriction, the alleged physical discomfort, anxiety, depression, and related consequences did not meet the required objective level of seriousness.

The court further held that Bryant did not allege that either defendant knew about his behavioral or mental-health conditions, knew that lack of exercise would cause the claimed consequences, or knew that Bryant had stopped going to the yard. The conditions-of-confinement theory also failed because the complaint did not plausibly allege that defendants denied him access to exercise or to appropriate hair ties or coverings, and denial of outdoor exercise and recreation in the circumstances alleged was not sufficiently serious to deny the basic necessities of life.

Disposition

Judge Kenneth M. Karas granted defendants’ motion to dismiss. Claims seeking damages under the Religious Land Use and Institutionalized Persons Act, and damages against defendants in their official capacities, were dismissed with prejudice. All other claims were dismissed without prejudice because this was the first merits adjudication of Bryant’s claims in this court. Bryant was given 30 days to file a third amended complaint containing all claims, defendants, facts, and exhibits he wanted the court to consider. The court did not decide defendants’ arguments concerning personal involvement or qualified immunity.