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Pratt v. Corrections Corp.

United States Court of Appeals, Eighth Circuit
Mar 7, 2008
267 F. App'x 482 (8th Cir. 2008)

Summary

holding that claims for injunctive relief and declaratory judgment are moot when prisoner/complainant is no longer in the facility in question

Summary of this case from Stanko v. Sheridan Cnty.

Opinion

No. 06-3556.

Submitted: March 3, 2008.

Filed: March 7, 2008.

Appeal from the United States District Court for the District of Minnesota.

Anthony Pratt, Pine Knot, KY, pro se.

Sarah Crippen Madison, Rebecca A. Chaffee, Best Flanagan, Minneapolis, MN, for Appellees.

Before WOLLMAN, RILEY, and GRUENDER, Circuit Judges.


[UNPUBLISHED]


Anthony Pratt, an inmate formerly in Wisconsin state custody and housed at the Prairie Correctional Facility (PCF) in Minnesota, appeals the district court's grant of summary judgment to defendants in his 42 U.S.C. § 1983 action on his claims regarding the denial of a prison diet containing Halal meat.

The Honorable Joan N. Ericksen, United States District Judge for the District of Minnesota, adopting the report and recommendations of the Honorable Arthur J. Boylan, United States Magistrate Judge for the District of Minnesota.

The district court originally dismissed Pratt's claims, but this court remanded for further proceedings. See Pratt v. Corr. Corp. of Am., 124 Fed.Appx. 465, 466-67 (8th Cir. 2005) (unpublished per curiam). Following the remand, Pratt filed an amended complaint, alleging that the Corrections Corporation of America (CCA) and various CCA-PCF officials violated his rights under the Religious Freedom Restoration Act (RFRA), the Religious Land Use and Institutionalized Persons Act (RLUIPA), and the First, Fifth, Eighth, and Fourteenth Amendments. Pratt alleged the following. He practices the Islam religion, which requires adherence to a Halal diet: permitted foods include non-animal products and special Halal meat, i.e., red meat, chicken, or turkey from animals that were blessed in the name of Allah before their slaughter. PCF agreed to offer Pratt special vegetarian meals, but the vegetarian diet was nutritionally inadequate; and further PCF breached a contract with him by failing to provide Halal meat. Following defendants' summary judgment motion and Pratt's response, the district court granted summary judgment in favor of defendants.

After de novo review, see Anderson v. Larson, 327 F.3d 762, 767 (8th Cir. 2003), we find that the district court properly granted summary judgment for defendants. First, Pratt's claims for injunctive and declaratory relief are now moot, as Pratt is in federal custody and is no longer subject to CCA policy. See Smith v. Hundley, 190 F.3d 852, 855 (8th Cir. 1999) (inmate's claims for declaratory and injunctive relief are moot when he is transferred to another facility and is no longer subject to alleged unlawful conditions). Second, we find that Pratt's claims brought under the First Amendment, RFRA, and RLUIPA all fail, because he did not show that defendants placed a "substantial burden" on his ability to practice his religion by failing to provide him with Halal meat. See Patel v. U.S. Bureau of Prisms, 515 F.3d 807, 810-12 n. 8 (8th Cir. 2008) (prison's meal plan regulations did not substantially burden Muslim inmate's free exercise rights where inmate had access to only vegetarian entrees, and some of those entrees he had to pay for himself). Third, the vegetarian diet did not violate Pratt's Eighth Amendment rights, as he did not rebut defendants' evidence that the meals were nutritionally adequate. See Berry v. Brady, 192 F.3d 504, 507 (5th Cir. 1999) (Eighth Amendment requires that inmates receive well-balanced meals containing sufficient nutritional value to preserve health). Finally, defendants did not breach any contractual duty by failing to provide a diet including Halal meat.

Accordingly, the judgment is affirmed.


Summaries of

Pratt v. Corrections Corp.

United States Court of Appeals, Eighth Circuit
Mar 7, 2008
267 F. App'x 482 (8th Cir. 2008)

holding that claims for injunctive relief and declaratory judgment are moot when prisoner/complainant is no longer in the facility in question

Summary of this case from Stanko v. Sheridan Cnty.

holding that claims for injunction relief and declaratory judgment are moot when prisoner/complainant is no longer in the facility in question

Summary of this case from Stanko v. Brewer

holding that a state inmate's claim for injunctive relief was moot upon his transfer to federal custody

Summary of this case from Parks v. Marcus

holding that a state inmate's claim for injunctive relief ordering prison officials to provide a diet containing Halal meat was moot upon his transfer to federal custody

Summary of this case from Livingston v. Warren Cnty.

concluding inmate's § 1983 claims for declaratory and injunctive relief were moot when he was transferred to another facility and was no longer subject to alleged unlawful conditions

Summary of this case from Brooks v. Roy

concluding inmate's 1983 claims for declaratory and injunctive relief were moot when he was transferred to another facility and was no longer subject to alleged unlawful conditions

Summary of this case from Looper v. Sanders

affirming the lower court's grant of summary judgment for the defendants on the ground that plaintiff inmate had failed to show a substantial burden

Summary of this case from Coleman v. Jabe
Case details for

Pratt v. Corrections Corp.

Case Details

Full title:Anthony PRATT, Appellant, v. CORRECTIONS CORPORATION OF AMERICA; Darren…

Court:United States Court of Appeals, Eighth Circuit

Date published: Mar 7, 2008

Citations

267 F. App'x 482 (8th Cir. 2008)

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