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Williams v. Hamilton County

United States District Court, E.D. Tennessee, Chattanooga

March 7, 2018

BENJAMIN LOGAN WILLIAMS, Plaintiff,
v.
HAMILTON COUNTY, TENNESSEE, et al., Defendants.

          MEMORANDUM

          CURTIS L. COLLIER, UNITED STATES DISTRICT JUDGE.

         Before the Court is Defendant Hamilton County, Tennessee's (“Hamilton County”) motion for judgment as a matter of law (Doc. 119) on Plaintiff Williams's claim under the Religious Land Use and Institutionalized Persons Act (the “RLUIPA”), 42 U.S.C. §§ 2000cc, et seq.-the only remaining claim against Hamilton County. Plaintiff responded in opposition (Doc. 121), and Hamilton County replied (Doc. 122). For the reasons explained below, the Court construes Hamilton County's motion as a motion for summary judgment and will GRANT the motion (Doc. 119).

         I. BACKGROUND

         This case arises out of the Defendants' alleged failure to provide Plaintiff with a kosher diet in accordance with Plaintiff's Jewish faith while he was incarcerated.[1] After a traffic stop in which officers believed Plaintiff to be under the influence of a stimulant, Plaintiff was incarcerated at the Hamilton County Jail on April 4, 2014, and remained there until April 14, 2014, when he was transferred to the Silverdale Detention Facility. He remained there until he was released from custody on May 1, 2014. Plaintiff subsequently filed suit against a number of entities, including Hamilton County, claiming he was denied a requested kosher diet while incarcerated. Plaintiff brought claims under the RLUIPA, 42 U.S.C. § 1983, and the Tennessee Constitution.

         Each party moved for summary judgment on Plaintiff's claims, and on April 27, 2017, the Court entered an order resolving each of those motions. (Doc. 114.) As part of that order, the Court granted summary judgment in favor of Hamilton County on each of Plaintiff's claims except for that brought under the RLUIPA. This is the only claim still pending against Hamilton County.

         On May 19, 2017, Hamilton County filed this motion for judgment as a matter of law (Doc. 119). Hamilton County represents that it has recently been informed that Plaintiff is seeking only declaratory relief against it, not monetary damages.[2] As a result, Hamilton County argues, Plaintiff's RLUIPA claim is moot, and Hamilton County should therefore be dismissed from the action.

         II. STANDARD OF REVIEW

         Hamilton County moves for judgment as a matter of law under Federal Rule of Civil Procedure 50. Rule 50(a)(1) provides:

         If a party has been fully heard on an issue during a jury trial and the court finds that a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue, the court may:

(A) resolve the issue against the party; and
(B) grant a motion for judgment as a matter of law against the party on a claim or defense that, under the controlling law, can be maintained or defeated only with a favorable finding on that issue.

         Hamilton County presumably brings its motion under this particular rule because the dispositive motion deadline has already passed, and Rule 50(a)(2) allows for the filing of motions for judgment as a matter of law “any time before the case is submitted to the jury.” Fed.R.Civ.P. 50(a)(2). Subsection (a)(1), however, specifically limits the court's ability to resolve such a motion until after “a party has been fully heard on an issue during a jury trial.” Fed.R.Civ.P. 50(a)(1) (emphasis added). Hamilton County is right that the case has yet to be submitted to the jury. But the trial itself has not yet begun. No party has therefore been “fully heard” on any issue during trial.

         Instead, the Court considers the motion before it under the summary judgment rule. Although Hamilton County's motion for summary judgment has already been ruled on, Rule 56 allows the Court to render judgment “independent of the motion.” Fed.R.Civ.P. 56(f). After giving notice of the court's intent to so rule and a reasonable time to respond, the court may: “(1) grant summary judgment for a nonmovant; (2) grant the motion on grounds not raised by a party; or (3) consider summary judgment on its own after identifying for the parties material facts that may not be genuinely in dispute.” Id. The Court will consider Hamilton County's motion under the last of these options.[3]

         Summary judgment is proper when “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). The moving party bears the burden of demonstrating no genuine issue of material fact exists. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986); Leary v. Daeschner, 349 F.3d 888, 897 (6th Cir. 2003). The Court should view the evidence, including all reasonable inferences, in the light most favorable to the nonmoving party. Matsushita Elec. Indus. Co., Ltd. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986); Nat'l Satellite Sports, Inc. v. Eliadis, Inc., 253 F.3d 900, 907 (6th Cir. 2001). To survive a motion for summary judgment, “the ...


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