(PC) Jackson v. Sacramento County Jail

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 | Elijah Lee Jackson, No. 2:21-cv-1814-KJM-DMC-P 12 Plaintiff, ORDER 13 v. Sacramento County Main Jail, 1S Defendant. 16 17 Plaintiff, a prisoner proceeding pro se, brings this civil rights action under 42 U.S.C. 18 | § 1983. The matter was referred to a United States Magistrate Judge as provided by Eastern 19 | District of California local rules. 20 On August 26, 2024, the Magistrate Judge filed findings and recommendations, which 21 | were served on the parties, and which contained notice that the parties may file objections within 22 | the time specified therein. Findings & Recommendations, ECF No. 25. Plaintiff filed timely 23 | objections to the findings and recommendations. Obj., ECF No. 26. 24 In accordance with the provisions of 28 U.S.C. § 636(b)(1)(C) and Local Rule 304, this 25 | court has conducted a de novo review of this case. Having reviewed the file, the court finds the 26 | finding and recommendations do not apply the correct legal standard. 27 Under the Free Exercise Clause of the First Amendment, incarcerated individuals retain 28 | their religious freedom while incarcerated, subject to limitations “aris[ing] both from the fact of

1 | incarceration and from valid penological objectives.” Fuqua v. Raak, 120 F.4th 1346, 1352 2 | (9th Cir. 2024) (citing O’Lone v. Estate of Shabazz, 482 U.S. 342, 348 (1987); Walker v. Beard, 3 | 789 F.3d 1125, 1138 (9th Cir. 2015)). To assert a Free Exercise claim, an incarcerated individual 4 | must show he has a sincerely held religious belief that was impinged upon by government action. 5 | dd. (citing Jones v. Slade, 23 F.4th 1124, 1144 (9th Cir. 2022); Walker, 789 F.3d at 1138). After 6 | this initial showing, the “burden shifts to the [defendant] to show that the regulation is reasonably 7 | related to legitimate penological interests.” Jones, 23 F.4th at 1144 (internal citation omitted). 8 | To determine if a defendant has made this showing, the court considers the factors set forth in 9 | Turner v. Safley, 482 U.S. 78 (1987): (1) whether there is a valid, rational connection between a 10 | state interest and the prison regulation; (2) whether prisoners have an alternative method of 11 | engaging in religious practice; (3) the impact accommodation of the asserted constitutional right 12 | would have on guards and other inmates; and (4) the absence of ready alternatives to the 13 | challenged regulation. 14 The applicable standard, therefore, calls for an analysis of the plaintiff’s beliefs to 15 | determine if they are sincerely held, to be followed by an analysis of the Turner factors if 16 | appropriate. 17 Accordingly, the court declines to adopt the findings and recommendations, ECF No. 25, 18 | and this matter is remanded to the magistrate judge for screening under the applicable standard 19 | described herein. 20 IT IS SO ORDERED. 21 | DATED: January 22, 2025. oUt 22 a STATES DISTRICT JUDGE 23 24