Schlemm v. Wall

Dist. Ct. erred in granting defendants-prison officials’ motion for summary judgment in plaintiff-prisoner’s action alleging that defendants violated Religious Land Use and Institutionalized Persons Act by denying plaintiff’s (member of Navajo Tribe) request for venison and use of multi-color headband during celebration of Tribe’s Ghost Feast, which defendants conceded was religious event. While Dist. Ct. found that absence of venison would not impose substantial burden on plaintiff’s religious exercise, summary judgment required Dist. Ct. to view all disputed facts in light most favorable to plaintiff, who indicated that venison played important role in Ghost Feast. Moreover, limited state of record failed to support defendants’ argument that increased expense at providing USDA-inspected venison was compelling reason to deny such request. Also, defendants failed to establish that plaintiff’s request for multi-colored headband related to their concern that such headband would act as signal of gang membership to other inmates.