Prisoner's Religious Claim Rejected Under PLRA

A case decided earlier this month by a Kentucky federal district court illustrates the procedural hurdles that prisoners face in bringing claims for religious accommodation, despite the enactment of RLUIPA. In Franklin v. Rees, 2005 US Dist. LEXIS 13578 (WD KY, July 1, 2005), a Sikh prisoner had filed grievances for over 3 years seeking a diet consistent with his religious beliefs and items he needed for religious worship. Even though the court concedes that "plaintiff has diligently pursued his quest to have his religious needs met while confined", it rejected his claim because the Prison Litigation Reform Act (PLRA), 42 USC 1997e(a), requires that a prisoner exhaust his administrative remedies before filing suit. Here, the court said, "he has failed to satisfy the PLRA's exhaustion requirement as his many grievances did not specifically name any of the individuals that he has named as defendants in his complaint."