Background
Walter Ray Beasley filed an amended civil-rights complaint alleging that, while detained at Riverside Regional Jail, kitchen supervisor T. Peyton failed to accommodate his religious dietary needs during Ramadan. He sought injunctive relief under the Religious Land Use and Institutionalized Persons Act, as well as monetary damages.
The Eastern District of Virginia granted Peyton’s motion to dismiss. Among other rulings, the district court concluded that Beasley’s transfer out of Riverside Regional Jail while the lawsuit was pending rendered his RLUIPA claim for injunctive relief moot. Beasley appealed but requested only injunctive relief on appeal.
The Court’s Holding
The Fourth Circuit affirmed in an unpublished per curiam opinion. Limiting its review to the issues Beasley raised in his informal brief, the court found no reversible error in the district court’s determination that his transfer from Riverside Regional Jail mooted his request for injunctive relief.
The court relied on Fourth Circuit precedent concerning the effect of a prisoner’s transfer on requests for prospective relief tied to conditions at a particular institution. It therefore left the dismissal order intact and decided the appeal without oral argument.
Key Takeaways
- A detainee’s transfer from the facility where the challenged conduct occurred generally moots a request for injunctive relief directed at conditions there.
- Because Beasley sought only injunctive relief on appeal, the Fourth Circuit did not disturb the dismissal based on his request for monetary damages.
- In a pro se appeal, the Fourth Circuit confines its review to issues preserved in the appellant’s informal brief.
Why It Matters
The decision reinforces that RLUIPA claims seeking facility-specific prospective relief may become moot when the claimant is transferred during litigation. Litigants challenging institutional practices should assess whether any recognized exception to mootness applies and carefully preserve each form of requested relief on appeal.
The opinion is unpublished and therefore is not binding precedent in the Fourth Circuit.