Knowles v. Pfister

In plaintiff-prisoner’s action alleging that defendant-prison warden violated Religious Land Use and Institutionalized Persons Act (RLUIPA) when he confiscated plaintiff’s “pentacle medallion” used by plaintiff to observe his Wiccan religion, Dist. Ct. erred in denying plaintiff’s request for issuance of preliminary injunction seeking return of said medallion. Instant medallion was small enough, when worn around neck, to comply with prison regulations regarding wearing of jewelry, and RLUIPA prohibits govt. from imposing substantial burden on plaintiff’s religious exercise, where, as here, plaintiff claimed that wearing said medallion would protect him from “harm, evil entities and negative energy.” Moreover, record failed to support defendant’s claim that seizure of medallion was necessary to protect plaintiff from gang-related violence, where there was no showing that other inmates would see medallion that plaintiff had agreed to wear under his shirt. Ct. also rejected Dist. Ct.’s observation that seizure of medallion was harmless act because plaintiff had other means to observe his religion.