Lance Wood v. Keith Yordy

Plaintiff Lance Wood is an Idaho state prisoner with an apparent penchant for romantic (but, as all parties stress, not sexual) relationships with prison guards. When prison authorities found that he was utilizing chapel facilities for such purposes, they curtailed his opportunities for chapel access. He filed this action against individual prison officials under the Religious Land Use and Institutionalized Persons Act (“RLUIPA”), claiming they had imposed an unwarranted burden on his exercise of religion. The issue of first impression in this circuit is whether he may seek damages against prison officials in their individual capacities. We agree with the unanimous conclusion of all of the other circuits that have addressed the issue that such a claim may not be maintained. This is principally because RLUIPA was enacted pursuant to Congress’s constitutional powers under the Spending Clause, and the individual defendants are not recipients of any federal funds. See, e.g., Stewart v. Beach, 701 F.3d 1322, 1335 (10th Cir.2012).

Wood also claims a violation of his First Amendment rights, alleging the defendants acted in retaliation for an earlier suit, in which he prevailed…