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Media Alerts - Davila v. Gladden
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February 9, 2015
  Davila v. Gladden
Headline: Eleventh Circuit holds the Religious Freedom Restoration Act (RFRA) does not authorize money damages against government officers in their official capacity and even if the act authorized liability in their individual capacity, the officers in this case would be entitled to qualified immunity.

Area of Law: Constitutional

Issue(s) Presented: Whether RFRA authorizes money damages against officers in either their official or individual capacities.

Brief Summary: Appellant, Anthony Davila ("Davila"), filed a pro se complaint against a number of prison officials in their official and individual capacities, seeking money damages and injunctive relief. Davila alleged the prison officials violated his rights under RFRA. The district court dismissed all Davila's claims for money damages, and granted summary judgment as to the remaining claims for injunctive relief. The Eleventh Circuit reversed the district court's grant of summary judgment on the injunctive relief claim and affirmed the remainder of the district court's rulings.

Extended Summary: Davila, a federal prisoner and Santeria priest, was denied multiple requests for his personal set of beads and shells, which he claimed were infused with the spiritual force "Ache." The prison officials justified their denial based on a prison policy that requires all religious items to be brought in through approved vendors. Davila claimed the denial by prison officials violated his rights under the First Amendment and RFRA. The district court dismissed Davila's claims for money damages under RFRA and the First Amendment, and granted summary judgment in favor of the prison officials on all other claims.

The Eleventh Circuit, in addressing two issues of first impression, determined that Davila could not recover money damages under RFRA from prison officials in either their official or individual capacities. The court reasoned that Congress did not unambiguously waive sovereign immunity to authorize suits for money damages against officers in their official capacity when enacting RFRA. The court declined to address whether RFRA authorizes money damages against government officials in their individual capacity because the officers in this case would be entitled to qualified immunity. The Eleventh Circuit affirmed the dismissal of Davila's remaining claims, including its denial of monetary damages under RFRA. However, the Eleventh Circuit reversed the district court's grant of summary judgment on Davila's RFRA claim for injunctive relief.

To view full opinion: http://media.ca11.uscourts.gov...b/files/201310739.pdf

Panel: Martin, Julie Carnes and Anderson, Circuit Judges

Argument: October 17, 2014

Date of Issued Opinion: January 9, 2015

Docket Number: 13-10739

Decided: Affirmed in Part, Reversed in Part and Remanded

Case Alert Author: Astrid Lopez, Maria Catala, David Schnobrick, Khristopher Salado

Counsel (if known): John Christopher Amabile for Appellant
Sanjay S. Karnik for Appellees


Author of Opinion: Martin, Circuit Judge

    Posted By: Gary Kravitz @ 02/09/2015 01:38 PM     11th Circuit  

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