Aracely Hernandez, a former Oregon state prisoner, filed a lawsuit under 42 U.S.C. § 1983 and the Religious Land Use and Institutionalized Persons Act (RLUIPA). She alleged that prison officials denied her accommodations for Ramadan and confiscated religious property. While her appeal was pending, Hernandez was released from prison. The defendants moved to dismiss the case as moot, arguing that her release ended the controversy regarding injunctive relief. The district court had previously granted summary judgment against Hernandez on her claims for damages. The Ninth Circuit now reviews whether the district court correctly applied the Prison Litigation Reform Act's exhaustion requirements, whether RLUIPA allows for monetary damages, and whether the case remains live after Hernandez's release.
The panel addressed three distinct legal issues. First, regarding mootness, the court held that Hernandez's release from prison mooted her claims for injunctive relief. Citing Alvarez v. Hill, the court explained that an inmate's release generally ends the controversy because the plaintiff is no longer subject to the challenged conditions or policies. Consequently, any request for access to religious books or challenges to confiscation policies must be dismissed. Second, on the First Amendment claim for damages, the court affirmed the district court's summary judgment. The court emphasized that the Prison Litigation Reform Act requires mandatory and timely exhaustion of administrative remedies. Under Oregon Administrative Rule 291-109-0205(1), grievances must be received within 14 days of the incident. Because Hernandez failed to file her grievance within this strict deadline, her claim for damages was barred. The court also declined to consider a new argument raised for the first time on appeal regarding COVID-19 restrictions, noting that arguments not presented to the district court are waived. Third, regarding the RLUIPA claim, the court affirmed summary judgment on damages. Citing Al Saud v. Days, the court clarified that RLUIPA does not authorize monetary damages; only injunctive relief is available. Furthermore, even for injunctive relief, the court found summary judgment proper because Hernandez failed to raise a triable dispute showing that the defendants' actions imposed a substantial burden on her religious exercise, as required under Warsoldier v. Woodford.
This decision effectively ends the litigation without a judicial determination on the merits of the underlying religious liberty allegations. For prisoners and their advocates, the ruling reinforces the strict procedural requirements of the PLRA, where missing a grievance deadline by even a day can bar a damages claim entirely. It also clarifies that RLUIPA cannot be used as a vehicle for monetary compensation in prison settings, limiting the remedy to court orders changing policy. Finally, the mootness ruling means that once a prisoner is released, they generally cannot seek injunctive relief regarding past prison conditions, leaving them with only damages claims that remain subject to strict exhaustion rules.
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