Malik Muntaqim v. Dexter Payne and Wendy Kelley, Directors, Arkansas Department of Correction; Anthony Jackson…

Summary

The court affirmed dismissal of Muntaqim’s civil-rights complaint because his allegations did not establish viable constitutional or religious-exercise claims and the appellees were therefore immune from liability. The court held that withholding some religious publications, destroying five books, and alleged failures to follow prison procedures did not sufficiently plead retaliation, a protected liberty interest, unequal treatment, a denial of court access, a substantial burden on religious exercise, or an Establishment Clause violation. The court also concluded that the complaint failed to allege ultra vires conduct sufficient to overcome official-capacity immunity.