Monroe v. Rockland County District Attorney's Office

Background

Michael J. Monroe, who was detained at the Rockland County Correctional Facility and represented himself, alleged that Defendants interfered with his religious practice. The court understood his complaint to assert claims under 42 U.S.C. § 1983, a statute allowing claims against state actors who violate federal rights, and under the Religious Land Use and Institutionalized Persons Act (RLUIPA).

Monroe alleged that he is Muslim and that he tried several times to call his girlfriend so he could obtain his prayer rug, Quran, and other Islamic religious materials from the home they shared. He alleged that Assistant District Attorney Veronice Phillips then charged him with another felony for violating an order of protection by contacting a witness. He also alleged that he told his attorney, Phillips, a public defender, and Town of Ramapo Justice Court Judge Fried that he needed the religious materials, but was not told how to retrieve them. Monroe said that without his prayer rug he had difficulty praying five times a day, could not read or recite from the Quran, and was not provided those items by the facility chaplain. He sought money damages and injunctive relief.

Screening and legal standards

Because Monroe was a prisoner proceeding without paying the filing fee in advance and sued governmental defendants, the court screened the complaint under the Prison Litigation Reform Act. That screening requires dismissal of claims that are frivolous, fail to state a legally sufficient claim, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. The court also explained that although self-represented complaints are read generously, they must still provide enough factual detail to make a claim plausible.

For the First Amendment free-exercise claim, the court described the relevant question as whether a defendant significantly interfered with Monroe’s religious beliefs. For RLUIPA, the court explained that the government generally may not substantially burden an institutionalized person’s religious exercise unless the burden serves a compelling governmental interest through the least restrictive means. The court also stated that RLUIPA does not permit money damages against state officials in their official capacities and does not provide a private claim against state officials in their individual capacities under Second Circuit precedent.

Claims against Phillips and the District Attorney’s Office

The court dismissed Monroe’s claims against Assistant District Attorney Phillips and the Rockland County District Attorney’s Office. It held that the claims were based on actions within the scope of prosecutorial duties and connected with the conduct of a trial. Prosecutors have absolute immunity from civil damages claims under § 1983 for such conduct. The court further stated that, even if prosecutorial immunity did not apply, RLUIPA would not permit the requested money damages against individual defendants.

The court characterized the claims as seeking monetary relief from an immune defendant and as frivolous under the prisoner-screening statutes. The opinion did not decide whether Monroe’s allegations ultimately established a First Amendment or RLUIPA violation.

Leave to amend and disposition

Because Monroe might be able to state a valid free-exercise claim against appropriate prison officials or a valid RLUIPA claim against an appropriate government entity, the court granted him sixty days to file an amended complaint. The amended complaint had to replace, rather than supplement, the original complaint and identify the defendants involved, the relevant facts, dates, locations, alleged injuries, and requested relief. The court explained that unknown defendants could be identified as “John Doe” or “Jane Doe,” subject to the applicable time limit for bringing the claims.

The court dismissed Monroe’s claims against the Rockland County District Attorney’s Office and Veronice Phillips. It granted leave to file an amended complaint and directed that no summons issue at that time. It warned that failure to file a compliant amended complaint within sixty days, absent good cause, would result in dismissal for failure to state a claim.