In Chambers v. Steed, 2006 U.S. Dist. LEXIS 52920 (D. Kan., July 25, 2006), a Kansas federal district court rejected a prisoner's claim that his rights were violated because his segregated confinement prevented him from attending Friday prayer services.
In Andreola v. Wisconsin, 2006 U.S. Dist LEXIS 52968 (ED Wis., July 19, 2006), a Wisconsin federal district court held that federal law precludes the award of compensatory damages in RLUIPA claims by prisoners alleging merely mental or emotional injury. However the court refused to grant defendants summary judgment on a punitive damages claim. The decision came in a long-running suit in which a prisoner alleged that he was denied a kosher diet while incarcerated. In Magistrate Judge P.A. v. Miami-Dade County, 2006 U.S. Dist. LEXIS 52595 (SD Fla., May 16, 2006), a Florida federal district court similarly held that, despite 42 USC 1997e(e), nominal and punitive damages may be recovered for free exercise violations, even though there are no physical injuries from the violations.
In Martinez v. Ortiz, 2006 U.S. Dist. LEXIS 52350 (D. Colo., July 31, 2006), a Colorado federal district court permitted a Native American prisoner to proceed with a claim for injunctive relief, but not for monetary relief, in his free exercise claim stemming from limitations placed on his religious practices.
In Madison v. Kilbourne, 2006 U.S. Dist. LEXIS 52994 (WD Va., July 18, 2006), a Virginia federal district court rejected an inmate's claims that he was denied his rights under the First Amendment and RLUIPA when on one day prison authorities denied him two kosher meals.
