Background
Lawrence Hamby, a practitioner of Hasidic Judaism, filed numerous grievances and a religious-accommodation request while incarcerated at the Iowa State Penitentiary. He alleged that the Iowa Department of Corrections prevented him from practicing his religion, including by denying access to religious items and practices such as a mikveh and, for a time, wax candles with open flames.
Hamby sued under the Religious Land Use and Institutionalized Persons Act and 42 U.S.C. § 1983, seeking prospective relief and damages from IDOC, Iowa, and several corrections officials. The district court granted summary judgment to the defendants based on sovereign immunity, failure to exhaust administrative remedies, mootness following Hamby’s transfer to another prison, the statute of limitations, and the merits of certain claims.
The Court’s Holding
The Eighth Circuit affirmed in part, reversed in part, and remanded. It held that sovereign immunity did not bar Hamby’s RLUIPA claims for prospective relief against IDOC because Iowa had accepted federal prison funding and thereby consented to such suits. It also held that Hamby’s sworn declaration created a genuine factual dispute over whether he appealed, attempted to appeal, or was thwarted from appealing his accommodation request and 11 specified grievances. The district court improperly discounted that declaration as generalized and self-serving and improperly credited IDOC’s evidence at summary judgment.
The court further held that Hamby’s transfer did not necessarily moot prospective-relief claims against statewide officials Ken Pirc and Beth Skinner when the challenged conditions could continue at his new facility. It also concluded that the denial of a mikveh could constitute a continuing violation, making the related damages claims timely. The court nevertheless affirmed dismissal of all claims outside those tied to Hamby’s accommodation request and Grievance Nos. 213, 214, 224, 225, 226, 241, 285, 324, 358, 359, 366, and 385, including claims involving post-suit grievances, the discontinued candle restriction, stolen cottage cheese, and use of religious funds for attorney fees. It left qualified immunity for the district court to address on remand.
Key Takeaways
- A prisoner’s specific sworn account of filing appeals or being thwarted in the grievance process can create a genuine factual dispute over PLRA exhaustion despite missing prison records.
- A prison transfer does not moot prospective-relief claims when challenged conditions may persist and the defendants possess statewide authority to provide relief.
- Repeated denial of an allegedly required religious practice may qualify as a continuing violation, restarting the limitations period with each new violation.
Why It Matters
The decision reinforces that courts may not resolve credibility disputes at summary judgment merely because a prisoner’s declaration is self-serving or lacks documentary corroboration. Prison recordkeeping evidence alone does not establish non-exhaustion as a matter of law when the prisoner provides competent contrary evidence.
The ruling also clarifies that RLUIPA prospective-relief claims may proceed against a state corrections agency that accepted federal funding, and that transfers and limitations defenses require claim-specific analysis rather than categorical dismissal.