The court of appeals affirmed a judgment of the district court. The court held that a volunteer “Wiccan” or “pagan” chaplain lacked standing to assert a claim that the paid chaplaincy program of the California Department of Corrections and Rehabilitation discriminated in its provision of religious accommodations where the rights he asserted properly belonged to third party inmates.
The California Department of Corrections and Rehabilitation’s (CDCR) paid chaplaincy program employs Protestant, Catholic, Jewish, Muslim, and Native American clergy. Patrick McCollum, a volunteer “Wiccan” or “Pagan” chaplain and a group of California prison inmates challenged the program under 42 U.S.C. §1983, and McCollum also alleged claims under Title VII and the California Fair Employment and Housing Act.