Suit under Religious Freedom Restoration Act (RFRA) by Muslim prisoner alleging guards interfered with his daily prayers; qualified immunity may be asserted as a defense to an RFRA claim, but based on allegations of significant, deliberate, repeated, and unjustified interference with prayer, officers would not be entitled to qualified immunity.
Inmate alleged detention officer, animated by anti-Muslim animus, ignored religious exemption to prison’s beard shaving policy and forced him to shave his beard; inmate stated violation of rights under Free Exercise clause; that officer’s conduct would violate Free Exercise clause was clearly established, hence no qualified immunity; inmate stated group-based equal protection claim and strict scrutiny applied to that claim.
Plaintiff, a parolee, and an atheist, alleged he was forced to participate in religious activities by his parole officer and the director of the Mission where his parole officer directed him to make his residence; genuine disputes of fact on both Establishment and Free Exercise Clause claims precluded summary judgment; parole officer not entitled to qualified immunity on either claim because right to be free from state-sponsored religious coercion was clearly established; evidence sufficient for jury to find that Mission director was a state actor.