Maddox v. Love, No. 10-1139 (7th Cir. 2011)
Annotate this CaseThe inmate attended services until the prison cancelled African Hebrew Israelite services. The prison denied his grievance, blaming budget cuts. The Grievance Officer and Department Director upheld the denial on the merits. The inmate filed a pro se 42 U.S.C.1983 complaint against the chaplain and wardens, alleging violations of the First and Fourteenth Amendments, the Religious Land Use and Institutionalized Persons Act, 42 U.S.C. 2000cc, and the Illinois Constitution. The district court dismissed restructured Counts 2 and 3 (discrimination in allocation of religious budget)and entered summary judgment for defendants on Counts 1 and 4 (failure to provide reasonable access to religious materials and to provide group worship services). The Seventh Circuit vacated in part. The grievance gave officials fair notice and an opportunity to address the complaint, so Count 4 should not have been dismissed for failure to exhaust administrative remedies. The court’s characterization of Counts 2 and 3 was too narrow a reading of the complaint and led to premature dismissal at the screening stage. Dismissal of Count 1 was appropriate because the inmate only complained of a failure to provide religious services in his grievance, not a failure to provide religious materials, and did not properly exhaust that claim.
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