Czekalski v. NH Department of Corrections, Commissioner

CourtDistrict Court, D. New Hampshire
DecidedFebruary 28, 2022
Docket1:18-cv-00592
StatusUnknown

This text of Czekalski v. NH Department of Corrections, Commissioner (Czekalski v. NH Department of Corrections, Commissioner) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Czekalski v. NH Department of Corrections, Commissioner, (D.N.H. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Jason A. Czekalski

v. Case No. 18-cv-592-PB Opinion No. 2022 DNH 021 Helen Hanks, Commissioner, New Hampshire Department of Corrections

MEMORANDUM AND ORDER Jason A. Czekalski, a Jewish inmate at the New Hampshire Department of Corrections (“NHDOC”), sued the NHDOC Commissioner Helen Hanks after she denied his requests for various religious accommodations. Before me is the Commissioner’s motion for summary judgment on his claims that the Commissioner violated the Establishment Clause when she denied (1) his requests for delivery of food to his cell (so-called cell feeds) to accommodate his daily morning prayers and his observance of the Sabbath, and (2) his request to wear a head covering of his choice.1 I grant the Commissioner’s motion because Czekalski failed to exhaust his administrative remedies with respect to the cell feed claims, and his head covering claim fails on the merits.

1 Czekalski also alleged that the Commissioner violated his rights under the Religious Land Use and Incarcerated Persons Act (“RLUIPA”). I addressed the RLUIPA claims in a prior order, where I denied the Commissioner’s motion for summary judgment regarding cell feeds but granted it as to the head covering claim. See Czekalski v. Hanks, 2020 DNH 212, 2020 WL 7231358, at *22-*24 (D.N.H. 2020). I. BACKGROUND2 Czekalski has practiced his Jewish faith while incarcerated at the NHDOC. Czekalski prays before breakfast every morning

for about forty-five minutes to an hour. He claims that because he needs to pray, he cannot attend breakfast when his unit is called to the chow hall. Instead, he prepares his own breakfast from the food he buys in the commissary. He would prefer to have breakfast delivered to his cell, a process known as a “cell feed.” Czekalski also observes a weekly Sabbath beginning at sundown on Friday and ending at sundown on Saturday. He observes a prohibition on work during that time and also claims that he cannot leave his unit’s yard. That restriction means that he cannot walk to the chow hall for dinner on Friday during December and January (because of the early sunsets) and for any

meal on Saturdays. In lieu of chow hall meals, he eats food from the commissary, but he would prefer to have cell feeds. Czekalski also covers his head at all times as a part of his religious practice. Although the prison generally does not allow inmates to wear head coverings indoors, it makes an exception for inmates who wear yarmulkes. Czekalski keeps one

2 I provided a detailed overview of the case in my prior order addressing the parties’ cross-motions for summary judgment. See Czekalski, 2020 WL 7231358, at *2-*9. I summarize here only those facts relevant to the claims at issue in this motion. or two yarmulkes in his cell, and he wore a yarmulke for court appearances in this case. Still, Czekalski considers a snug knit cap, which inmates are allowed to wear outdoors, to be a

better head covering than a yarmulke because it stays on his head. Correctional officers have told him that he cannot wear a knit cap indoors. The prison had a three-step grievance procedure during the relevant time that began with Inmate Request Slips at Level 1. The next level, Level 2, is satisfied by making a grievance to the prison warden. Level 3 mandates the filing of a grievance with the Commissioner. The grievance policy required sufficient detail to show the nature of the complaint or request. Matters for grievance included requests for assistance or services, requests for consideration of a matter in which the inmate believed he was improperly or unfairly treated, and requests for

reconsideration. In February 2018, Czekalski filed a grievance in which he requested daily breakfast cell feeds to accommodate his morning prayer schedule. He also mentioned that he might demand additional cell feeds during the Sabbath and then raise the issue in a lawsuit. His request was denied at Level 1 because the prison chaplain was informed by a consulting rabbi that no cell feeds were needed for religious accommodation. Czekalski appealed the denial through the grievance system. The Commissioner responded as follows: Dear Resident Czekalski, In review of your request, cell feeds are not necessary to accommodate your religious needs. Sabbath does not by practice limit your ability to go to the designated meal times while still engaging in the 3 times a day prayer as others who practice your same faith are able to demonstrate [in] our facilities.

Doc. No. 113-1, at *5. Czekalski did not include in the record any further appeals about cell feeds. With respect to his head covering, Czekalski filed a grievance in November 2017, asking the prison staff to permit him to wear his knit cap as a religious head covering. After he became dissatisfied with the chaplain’s responses on the matter, he appealed. Director of Community Corrections Kim McKay responded on behalf of the Commissioner, stating that a “knit cap is not considered a religious head covering.” Doc. No. 113- 1, at *12. Czekalski has not included any other appeals pertaining to head coverings. II. STANDARD OF REVIEW Summary judgment is appropriate “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). A material fact is one that “‘carries with it the potential to affect the outcome of the suit.’” French v. Merrill, 15 F.4th 116, 123 (1st Cir. 2021) (quoting Santiago- Ramos v. Centennial P.R. Wireless Corp., 217 F.3d 46, 52 (1st Cir. 2000)). A material fact is in genuine dispute if “‘a

reasonable jury could resolve the point in the favor of the non- moving party.’” Id. (quoting Santiago-Ramos, 217 F.3d at 52). The court construes the record in the light most favorable to the nonmoving party. Benson v. Wal-Mart Stores E., L.P., 14 F.4th 13, 17 (1st Cir. 2021). Nevertheless, the court will not consider “conclusory allegations, improbable inferences, [or] unsupported speculation.” Lima v. City of E. Providence, 17 F.4th 202, 206 (1st Cir. 2021) (quoting Mulloy v. Acushnet Co., 460 F.3d 141, 145 (1st Cir. 2006)). III. ANALYSIS The Commissioner moves for summary judgment on Czekalski’s Establishment Clause claims. She argues that Czekalski did not

exhaust his administrative remedies with respect to those claims and that she is entitled to qualified immunity. Czekalski objects. I address the claims in turn. A. Cell Feed Claims Under the Prisoner Litigation Reform Act, a prisoner is barred from bringing claims challenging prison conditions under 42 U.S.C. § 1983 “until such administrative remedies as are available are exhausted.” 42 U.S.C. § 1997e(a). That requirement provides an affirmative defense that a defendant may raise. Jones v. Bock, 549 U.S. 199, 216 (2007). The defendant bears the burden of showing that administrative remedies were available and that the plaintiff failed to exhaust them. See

Casanova v. Duboi, 304 F.3d 75, 77 n.3 (1st Cir. 2002).

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Related

Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Santiago-Ramos v. Centennial P.R. Wireless Corp.
217 F.3d 46 (First Circuit, 2000)
Mulloy v. Acushnet Company
460 F.3d 141 (First Circuit, 2006)
Benson v. Wal-Mart Stores East L.P.
14 F.4th 13 (First Circuit, 2021)
French v. Merrill
15 F.4th 116 (First Circuit, 2021)
Lima v. City of East Providence
17 F.4th 202 (First Circuit, 2021)

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