An inmate who identifies as a Hasidic Jew will get another chance to pursue several claims that Iowa prison officials failed to accommodate his religious practices after a federal appeals court revived parts of his lawsuit.
Lawrence Hamby, who was incarcerated at the Iowa State Penitentiary from June 2009 to February 2023, alleged that the Iowa Department of Corrections denied requests for kosher meals, candles to light before Shabbat and Jewish holidays, access to a mikveh for ritual cleansing and the use of religious funds for attorney fees.
After exhausting the prison system’s internal grievance process, Hamby sued the department and several officials under the Religious Land Use and Institutionalized Persons Act, alleging violations of his religious rights.
The U.S. District Court for the Southern District of Iowa dismissed all of Hamby’s claims, finding that his grievances were untimely, improperly submitted, lacked merit or were moot because Hamby, by that time, had been transferred to a different prison.
In a decision issued this week, a three-judge panel of the U.S. Court of Appeals for the Eighth Circuit reversed key portions of that ruling, holding that Iowa waived sovereign immunity for claims brought under RLUIPA by accepting federal funding. The panel also found that the district court improperly concluded Hamby had failed to exhaust administrative remedies, saying the record showed he completed the required grievance process, including review by the department’s religious coordinator and appeals to the Statewide Religion Review Committee.
The appeals court also ruled that some of Hamby’s claims for prospective relief against state officials remain viable, while affirming the lower court’s dismissal of other claims.
The case was remanded to the district court for further proceedings consistent with the appeals court’s opinion.
