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Keywords

plaintiffdefendantinjunctionappealmotion
plaintiffdefendantjurisdictioninjunctionappealmotion

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Lozano; U.S. v.

Facts

Lozano, a Sunni Muslim, alleges that Texas prison officials violated his rights by denying him meals that comply with his religious beliefs, specifically a halal diet. After being transferred to the LeBlanc Unit, where his dietary needs were not accommodated, he filed suit seeking injunctive relief to restore his halal-compliant diet. The district court denied his request for a preliminary injunction and his motion for appointment of counsel, leading to this appeal.

As a Sunni Muslim, Lozano alleges that 'his religious beliefs compel him to' follow a halal diet. This diet requires adherents to (1) eat meat, but only meat that was 'blessed in the name of Allah when slaughtered'; (2) avoid pork, pork byproducts, monoglyceride, lecithin, or whey; (3) avoid fruits or vegetables treated with 'pesticides or harmful ingredients'; and (4) avoid any foods that are cross contaminated with any prohibited foods.

Issue

Did the district court err in denying Lozano's request for a preliminary injunction regarding his religious dietary needs under RLUIPA and the First Amendment?

Did the district court err in denying Lozano's request for a preliminary injunction regarding his religious dietary needs under RLUIPA and the First Amendment?

Rule

To obtain preliminary injunctive relief, a plaintiff must demonstrate (1) likelihood of success on the merits, (2) irreparable harm, (3) that the equities tip in his favor, and (4) that the injunction is in the public interest. Under RLUIPA, once a plaintiff shows a substantial burden on the exercise of religion, the defendant must demonstrate that the burden was in furtherance of a compelling government interest and the least restrictive means of furthering that interest.

To obtain preliminary injunctive relief, a plaintiff must demonstrate (1) likelihood of success on the merits, (2) irreparable harm, (3) that the equities tip in his favor, and (4) that the injunction is in the public interest.

Analysis

The court found that the district court correctly denied Lozano's First Amendment claim, as prisons are not required to accommodate specific religious dietary requests. However, it agreed that the district court failed to apply the proper burden-shifting framework for Lozano's RLUIPA claim, which requires a fact-specific inquiry into whether the burden on Lozano's religious exercise was justified by a compelling governmental interest.

As for the RLUIPA claim, however, we agree with Lozano that the district court failed to apply the proper burden-shifting framework under Holt v. Hobbs, 574 U.S. 352, 135 S. Ct. 853, 190 L. Ed. 2d 747 (2015). Once a plaintiff has shown a substantial burden on the exercise of his religion, the defendant must then demonstrate that the imposition of that burden '(1) [was] in furtherance of a compelling government interest; and (2) [was] the least restrictive means of furthering that compelling governmental interest.'

Conclusion

The court affirmed the district court's judgment regarding Lozano's First Amendment claim, vacated the dismissal of his RLUIPA claim, and remanded the case for further proceedings.

In sum, we AFFIRM the district court's judgment with respect to Lozano's First Amendment claim, DISMISS Lozano's appeal of the district court's denial of his motion for appointment of counsel for lack of appellate jurisdiction, VACATE the district court's judgment insofar as it dismissed Lozano's RLUIPA claim, and REMAND for further proceedings consistent with this opinion.

Who won?

The prevailing party is the defendants regarding the First Amendment claim, as the court upheld the district court's decision that prisons do not need to accommodate specific dietary requests.

The prevailing party is the defendants regarding the First Amendment claim, as the court upheld the district court's decision that prisons do not need to accommodate specific dietary requests.

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