Simpson v. Colbert

CourtDistrict Court, District of Columbia
DecidedAugust 21, 2024
DocketCivil Action No. 2021-0479
StatusPublished

This text of Simpson v. Colbert (Simpson v. Colbert) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Simpson v. Colbert, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JESSE RUSSELL SIMPSON,

Plaintiff,

v. Civil Action No. 1:21-cv-00479 (CJN)

NICOLE COLBERT, et al.,

Defendants.

MEMORANDUM OPINION

Jesse Russell Simpson alleges that the District of Columbia and various employees of the

D.C. Jail unlawfully denied him certain religious accommodations while he was incarcerated there.

Defendants move to dismiss on all claims and for partial summary judgment as to Simpson’s

common law claims against the District. See ECF No. 22. For the reasons stated below, the Court

grants in part and denies in part Defendants’ Motion.

I. Background

Simpson was incarcerated at the D.C. Jail for just over two months in the fall of 2020. See

Am. Compl., ECF No. 13-1 at 9, 18. During that period, he was a practitioner of Orthodox Therian

Shamanism, a religion “with similar beliefs to many Native American and Animism religions.”

Id. at 3. This religion, Simpson alleges, requires him to “wear an imitation Wolf tail, . . . display

Wolf imagery in his living quarters and mediate regularly around imagery of Wolves,” in order to

gain “the powers of animals” and avoid “eternal damnation.” Id. It “also requires him to maintain

a vegan and sustainably sourced diet and refrain from touching or handling animal products.” Id.

1 Simpson alleges that he was denied religious accommodations during his detention. His

primary complaints relate to his diet. He alleges that he “was not provided food he could eat for

41 of the first 48 meals while he was at D.C. Jail,” as a result of which he experienced “constant

hunger and extreme physical and mental discomfort,” losing over 10 pounds. Id. at 19. He also

claims he was also unable to possess wolf paraphernalia, including a wolf tail and wolf imagery.

Simpson’s amended complaint describes in detail the process by which he requested

dietary accommodations. In general, he would first ask staff at the cafeteria for a vegan meal. If

that did not happen, he was directed either to fill out a sick call form or to send a request form to

the Chaplain’s Office asking for religious accommodations. See Amended Compl., ECF No. 13-

1 at 10–11. In the event that the Chaplain’s Office denied such a request, he would file with the

Warden an emergency grievance or an appeal of that denial. Id. at 11. All told, he submitted at

least two sick call forms, three requests for religious accommodations, four emergency grievances,

and five appeals. Toward the end of his detention, he was generally provided with the meals he

requested.

In February 2021, Simpson filed this action pro se. After the resolution of various

preliminary matters, his amended complaint currently asserts claims against the District of

Columbia, Warden Lennard Johnson, Supervisory Chaplain Nicole Colbert, Reverend Keith

Venson, and certain unnamed D.C. Jail staff under 42 U.S.C. § 1983 (for violations of his First,

Fifth, and Eighth Amendment rights), and the Religious Freedom Restoration Act, 42 U.S.C. §§

2000bb, et seq.; against Colbert and Venson under 42 U.S.C. § 1985(3); and against all defendants

under various common law theories.

2 Defendants move to dismiss all claims and for partial summary judgment on Simpson’s

common-law claims (on the ground that he failed to provide them with statutorily required notice

before filing suit). See ECF No. 22.

II. Analysis

A. The District of Columbia

1. RFRA Claims

In 1993, Congress passed the Religious Freedom Restoration Act (RFRA) to “provide very

broad protection for religious liberty.” Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682, 693

(2014). RFRA provides that “[g]overnments shall not substantially burden a person’s exercise of

religion even if the burden results from a rule of general applicability,” unless the government

“demonstrates that application of the burden to the person—(1) is in furtherance of a compelling

governmental interest; and (2) is the least restrictive means of furthering that compelling

governmental interest.” 42 U.S.C. §§ 2000bb–1(a), (b); see also id. at § 2000cc–1(a). A person

whose religious exercise has been burdened “may assert that violation as a claim . . . in a judicial

proceeding and obtain appropriate relief against a government.” Id. at § 2000bb–1(c). RFRA

applies to the District of Columbia. Id. at § 2000bb–2(2).

The District acknowledges that it is subject to RFRA, but contends that it has not waived

sovereign immunity for damages claims under RFRA. Simpson’s only response is that the

District, as a “covered entity,” can be made to give “all appropriate relief” under the statute. See

Pl. Memo in Opp. to Mot. to Dismiss, ECF No. 23 at 5.

The District is correct. A plaintiff cannot pursue damages from the District of Columbia

without an express waiver of sovereign immunity from Congress. See United States v. Mitchell,

463 U.S. 206, 212 (1983); see also Anderson v. Carter, 802 F.3d 4, 8 (D.C. Cir. 2015); see

Metro. R. Co. v. District of Columbia, 132 U.S. 1, 9 (1889) (“[T]he sovereign power of this

3 qualified state is not lodged in the corporation of the District of Columbia, but in the government

of the United States.”). Courts must “strictly construe[]” any waiver of sovereign immunity, “in

terms of its scope, in favor of the sovereign.” Lane v. Peña, 518 U.S. 187, 192 (1996). RFRA

does not contain a clear, unambiguous waiver of sovereign immunity for money damages,

whether as to the United States, see Webman v. Fed. Bureau of Prisons, 441 F.3d 1022, 1026

(D.C. Cir. 2006), or the District of Columbia. Simpson’s RFRA damages claims against the

District must therefore be dismissed.

2. Section 1983

Courts assess § 1983 claims against municipalities (including the District of Columbia)

under a two-step process. First, a court must determine whether the complaint states a plausible

claim for a predicate constitutional violation. See Baker v. District of Columbia, 326 F.3d 1302,

1306 (D.C. Cir. 2003) (citing Collins v. City of Harker Heights, 503 U.S. 115, 124 (1992)).

Then, the court must decide whether the complaint states a plausible claim that the constitutional

violation was caused by a custom or policy of the municipality. Id.

Defendants do not contest (for purposes of their Motion) that Simpson adequately alleges

violations of the First and Fifth Amendments. But they do argue that Simpson has failed

adequately to allege municipal liability for those claims. And they argue that Simpson has failed

to allege an Eighth Amendment violation.

a.

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