Smith v. Pugh: Caution Against “Received-By” Deadlines for Prisoner Filings and the Centrality of Medical Causation in Ramadan-Meal RLUIPA/Eighth Amendment Claims

1. Introduction

Walter Smith, a federal prisoner formerly housed at Stanley Correctional Institution in Wisconsin, sued prison officials (including Jeffrey Pugh) after the prison accommodated Ramadan fasting with refrigerated “meal bags” that prisoners could not reheat once served. Smith alleged that eating the meals cold aggravated his irritable bowel syndrome (IBS), effectively pressuring him to break his fast.

He raised three core theories:

• RLUIPA and First Amendment: the refusal to provide hot meals or allow reheating imposed a substantial burden on his religious exercise.
• Eighth Amendment: the refusal reflected deliberate indifference to his serious medical needs.
• Procedure: the district court should have recruited counsel (to secure experts), and it should not have treated defendants’ facts as undisputed given the prison-mailbox rule.

The district court granted summary judgment to defendants. On appeal, the Seventh Circuit affirmed, while offering an important administrative caution about “received-by” deadlines imposed on incarcerated litigants.

2. Summary of the Opinion

The Seventh Circuit held:

• No abuse of discretion in denying recruitment of counsel at the time it was sought, under Pruitt v. Mote.
• The court did not decide whether the prison-mailbox rule applies when a district court orders prisoner filings to be “received” by a specific date; instead, it affirmed because summary judgment was still proper even considering Smith’s materials.
• On the merits, Smith failed to produce evidence that meal temperature caused his IBS symptoms; without causation, he could not show a “meaningful negative consequence” sufficient to establish a substantial burden under RLUIPA/Free Exercise.
• His Eighth Amendment claim failed because medical staff consistently evaluated and treated him, and no evidence showed their approach was outside the bounds of professional judgment.

3. Analysis

3.1 Precedents Cited (and How They Shaped the Decision)

A. Counsel recruitment and litigation competence

• Pruitt v. Mote (en banc): Anchored the two-part inquiry (plaintiff’s competence versus case difficulty) and limited appellate review to the record as it stood when counsel was denied. The panel relied on this to uphold the denial, emphasizing Smith’s demonstrated capability and uncertainty (at that stage) about the need for expert testimony.

B. Summary judgment standards and affirmance on alternate grounds

• Thompson v. Holm: Cited for de novo review of summary judgment and for its Ramadan context in the substantive religious-burden analysis (discussed below).
• Levy v. Marion Cnty. Sheriff: Supported the panel’s authority to affirm on any ground supported by the record, as long as the issue was presented below and the nonmovant had a chance to contest it.

C. Prison-mailbox rule versus docket-control authority

• Houston v. Lack: Provided the rationale for treating prisoner filings as “filed” when delivered to prison officials, since prisoners cannot control delays after handoff.
• Censke v. United States: Recognized the prison-mailbox rule’s extension beyond notices of appeal and collected authorities; also reflected the Seventh Circuit’s tendency to read limitations narrowly.
• Fex v. Michigan: Supplied the counterweight—an acknowledgment that mailbox principles may yield to “clear directive language,” relevant to whether a court can require “receipt” by a date certain.
• Williams v. DeJoy: Supported the district court’s inherent authority to manage its docket, including setting and enforcing deadlines.

The panel synthesized these authorities to explain the tension: mailbox-rule fairness versus explicit “received-by” orders and docket management. It avoided a definitive holding, but its caution to district judges signals sensitivity to the practical problems created by receipt-based deadlines in prisoner litigation.

D. RLUIPA / Free Exercise: defining “substantial burden”

• West v. Radtke: Provided the governing RLUIPA framework and the Seventh Circuit’s formulation of “substantial burden” as a forced choice between religious compliance and a meaningful negative consequence.
• Holt v. Hobbs and Burwell v. Hobby Lobby Stores, Inc.: Used (via West v. Radtke) to ground the “meaningful negative consequence” test and to note RLUIPA’s breadth relative to the First Amendment.
• Thompson v. Holm and Jones v. Carter: Ramadan meal denial and halal-meat denial cases invoked by Smith to argue a substantial burden existed. The panel distinguished them: in those cases, the burden was tied to the denial of religiously compliant food itself, whereas Smith’s theory depended on proving medical causation (cold food → IBS flare → pressure to break fast).
• Soc'y of Divine Word v. U.S. Citizenship & Imig. Servs.: Cited for the proposition that because RLUIPA is more protective than the First Amendment, failure under RLUIPA generally implies failure under Free Exercise in the prison context addressed by the court.

E. Medical causation and the limits of lay and speculative expert testimony

• Pearson v. Ramos: Used to reject lay testimony as competent proof of medical causation; Smith’s belief in a temperature-symptom link could show correlation but not causation.
• Myers v. Illinois Cent. R. Co.: Supported the principle that speculative or tentative expert opinions (not establishing causation with sufficient certainty amid multiple possible causes) do not create a triable issue.

F. Eighth Amendment: deliberate indifference and deference to medical judgment

• Farmer v. Brennan: Provided the deliberate-indifference standard—knowledge of and disregard for a substantial risk of serious harm.
• Lockett v. Bonson: Framed disputes over adequacy of treatment as challenges to medical decision-making.
• Snipes v. DeTella: Quoted (via Lockett v. Bonson) for analyzing a doctor’s deliberate choice of treatment approach.
• Pyles v. Fahim: Supplied the “no minimally competent professional” benchmark and the deferential posture courts take toward professional medical judgment absent extreme departure from standards.

3.2 Legal Reasoning

A. Recruitment of counsel

Applying Pruitt v. Mote, the panel focused on what the district court knew when it denied counsel: Smith appeared able to litigate, expert testimony was not yet clearly essential, and Smith had not shown inability to contact witnesses. Later developments (summary judgment needs) could not retroactively make the denial an abuse of discretion because appellate review is constrained to the record at the time of decision.

B. Filing deadline dispute and the prison-mailbox rule

The district court had ordered it would consider Smith’s response materials only “if received by January 9, 2024,” but Smith delivered them to prison staff on January 8. The panel acknowledged the rationale of Houston v. Lack and its extensions (including Censke v. United States), while also recognizing the possible limiting force of explicit “received-by” language per Fex v. Michigan and the court’s docket authority per Williams v. DeJoy.

Crucially, the panel avoided a definitive doctrinal answer because it concluded the outcome would not change: even considering Smith’s materials, summary judgment was still proper. Nonetheless, it issued an institutional caution discouraging receipt-based deadlines for prisoners.

C. Evidence gatekeeping: Rule 26/37 and expert reports

Smith attached two proposed expert reports, but the district court excluded them for failure to properly disclose experts under FED. R. CIV. P. 26(a)(2). The panel noted that exclusion is typical under FED. R. CIV. P. 37(c)(1) unless the failure is “justified or harmless,” and it observed the district court did not expressly address those factors.

The panel again bypassed a definitive procedural ruling: even assuming the reports were considered, they did not create a genuine dispute of material fact on causation.

D. RLUIPA / Free Exercise: why causation mattered here

Under West v. Radtke, a “substantial burden” exists when policy forces a prisoner to choose between violating religion and suffering a meaningful negative consequence. Smith’s “negative consequence” theory was not merely discomfort from cold food; it was medically aggravated IBS that allegedly pressured him to break the fast.

That structure made medical causation essential. The panel found causation missing because:

• Medical records reflected ongoing IBS complaints even after reheating was allowed (undercutting Smith’s causal narrative).
• Lay testimony could not establish the medical link (Pearson v. Ramos).
• The nutritionist report addressed food-safety policy, not whether cold meals caused IBS symptoms.
• The gastroenterologist’s statement that cold meals “may trigger” symptoms was too speculative to create a triable issue (Myers v. Illinois Cent. R. Co.).

Without evidence that cold meals caused the alleged health penalty, Smith could not show the prison “attach[ed] some meaningful negative consequence” to his Ramadan practice in the way required by West v. Radtke.

E. Eighth Amendment: treatment was continuous, and medical judgment controlled

The panel assumed IBS was a serious medical condition and focused on deliberate indifference. The record showed repeated evaluation and interventions (medications, blood work, colonoscopy referral, hydration advice). Under Pyles v. Fahim, courts defer unless no minimally competent professional would respond similarly.

Smith’s theory—allow reheating as necessary medical accommodation—failed largely for the same reason as the RLUIPA claim: insufficient evidence that meal temperature caused the IBS flares, plus documented ongoing symptoms even after reheating was permitted. Thus, no reasonable jury could find conscious disregard of a substantial risk under Farmer v. Brennan.

3.3 Impact

A. Procedural administration: “received-by” deadlines and prisoners

Although the panel did not create a binding rule (and expressly avoided deciding the mailbox-rule question), its caution is operationally significant: receipt-based deadlines predictably collide with the logic of Houston v. Lack because prisoners cannot control institutional mailing delays. This language may be cited persuasively by litigants seeking:

• deadline orders framed in “mailed by” or “delivered to prison officials by” terms;
• relief from missed “received-by” deadlines attributable to prison mail systems; and
• local practices that harmonize docket control with access-to-courts concerns.

B. Substantive prison-religion litigation: when medical harm is the burden

The opinion underscores a practical evidentiary dividing line: where the alleged substantial burden is not a direct denial of religiously compliant food (as in Thompson v. Holm and Jones v. Carter), but instead hinges on health consequences, the claim may rise or fall on competent medical causation proof.

C. Expert evidence: speculation is not enough

The panel’s discussion reinforces that tentative phrasing (“may trigger”) is vulnerable at summary judgment where multiple causes exist (fasting itself, hydration changes, meal timing), aligning with the approach in Myers v. Illinois Cent. R. Co.. For future litigants, expert opinions must connect the dots with sufficient medical certainty and grapple with alternative causes reflected in the record.

4. Complex Concepts Simplified

• RLUIPA: A federal statute that gives prisoners robust protection for religious exercise. If the prison places a substantial burden on religious exercise, the prison must justify it as the least restrictive means of advancing a compelling interest.
• Substantial burden: Not every inconvenience qualifies. The burden must pressure a person to violate their faith by attaching a serious downside to religious compliance (here, alleged medical harm that would push Smith to break his fast).
• Prison-mailbox rule: Under Houston v. Lack, certain prisoner filings count as filed when handed to prison staff for mailing, because the prisoner can’t control later delays.
• Summary judgment: The case ends without trial if there is no genuine dispute of material fact requiring a jury.
• Deliberate indifference: More than negligence or disagreement with treatment; it requires knowing about a serious risk and ignoring it (Farmer v. Brennan).
• Medical causation proof: Courts generally require medical evidence—not just personal belief—to show that a specific condition was caused by a particular factor (Pearson v. Ramos).

5. Conclusion

Smith v. Pugh affirms summary judgment against a prisoner who alleged that refrigerated, non-reheatable Ramadan meal bags both burdened his religious exercise and worsened his IBS. The court’s central substantive move was evidentiary: because Smith could not show competent medical causation between meal temperature and IBS flares, he could not establish the “meaningful negative consequence” needed for a RLUIPA/Free Exercise substantial-burden claim, and he likewise could not show deliberate indifference under the Eighth Amendment given ongoing treatment and deference to medical judgment.

Procedurally, the decision is notable for its practical warning: district courts should avoid imposing prisoner deadlines keyed to when filings are “received,” because the logic of Houston v. Lack highlights prisoners’ lack of control over mail delays—even though the panel did not finally resolve the doctrinal scope of the mailbox rule in that setting.