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University of Utah, College of Law

The evolution of legal traditions in the Middle East will be examined, analyzed and discussed through the lens of multi-disciplinary readings reflecting the law, history, culture, human rights, and contemporary political dilemmas.

University of Washington, School of Law

University of Pennsylvania

UCLA, School of Law

This course introduces the field of Islamic law. Islamic law is one of the oldest and most significant legal systems in the contemporary age, and this course is designed to give students a firm grounding in its principles, concepts, and doctrines. We will study the history, theory, and the role of Islamic law in the contemporary age. No previous familiarity with the field is necessary, and there are no course prerequisites. All readings are in English. The course will be divided into two main parts: the first will deal with Islamic law in the classical context, while the second will examine the role of Islamic law in the contemporary age. The first half of the course is oriented towards the historical legacy and theoretical framework of the Islamic legal tradition with a special emphasis on the development of the various schools of law. In the second half, we will study the challenges of modernity and Islamic law in the contemporary age, and will examine issues related to Islamic public international law, human rights, women and gender, and violence.

University of Kansas School of Law

Examines the history, doctrine, texts, and role of Islamic law throughout the world. The course focuses on the background and birth of the Arab-Islamic Empire, the life and times of the Prophet Muhammad, the development of Islam, the Moghul and Ottoman Empires, the Qurʾān and Sunna and other sacred texts, the principal schools of Islamic law, the status of women and religious minorities, and basic principles of some of the substantive areas of law, including criminal, family, inheritance, contract, business, and banking law.

University of Toronto

The Plaintiff, the Muslim Community Association of Ann Arbor, challenged the Pittsfield Charter Township, the Township Board, Township Supervisor Mandy Grewal, and six Township Board of Trustees Members for their refusal to re-zone the area surrounding the Plaintiff so that the Plaintiff could expand and build a school. Although an independent outside planner endorsed the rezoning, the Plaintiff alleged that the Respondents denied rezoning due to concerns from community members, stemming largely from an animus to the Islamic faith. By denying the rezoning proposal on this basis, the Plaintiff claimed that the Respondents discriminated against the organization in violation of the Religious Land Use and Institutionalized Persons Act, the Fourteenth and Fifth Amendments of the U.S. Constitution, and "state law claims" in the Michigan state constitution. The Respondents filed a 12(b)(6) motion to dismiss. The District Court determined that the Plaintiff sufficiently pleaded the Township Board of Trustees' individual liability under Section 1983. However, the District Court dismissed the other claims alleging violations of RLUIPA, the US Constitution, and the Michigan Constitution.

The Plaintiff, the Equal Employment Opportunity Commission, represented a number of Somali Muslims working at a JBS-owned beef plant in Grand Island, Nebraska. The Plaintiff filed a Title VII discrimination claim against the Respondent-employer, alleging that the Respondent failed to provide Muslim employees with time to pray during sunset and also denied them prayer breaks during Ramadan. The District Court ultimately agreed with the Respondent-employer, deciding that the Muslim workers did not face undue discrimination because the accommodation of their prayer breaks would cause "undue hardship" to the employer because it would lead to unsafe meat curating practices and other dangers to the non-Muslim employees at the plant.

Plaintiff John Walker Lindh, a convicted "American Taliban," challenged prison policies that allowed for individual prayer in cells, but banned group congregation for prayer due to "security concerns." The Plaintiff sued the warden of the Federal Correctional Institution of Terre Haute, Indiana, alleging violations of the Religious Freedom Restoration Act. The District Court found that the Plaintiff did have sincerely held religious beliefs, and therefore turned its inquiry to whether the ban on group prayer furthers the compelling interest of security and is the least restrictive means of furthering that compelling governmental interest. The District Court ultimately determined that the warden-Respondent failed to establish that the total ban on daily congregational prayer by the Plaintiff was the least restrictive means of meeting the warden's security concerns.

The Plaintiffs, three Muslim individuals (Hamid Raza, Mohammad Elshinawy, Asad Dandia), two mosques (Masjid Al-Ansar, Masjid at-Taqwa), and a non-profit Muslim organization (Muslims Giving Back), alleged that the NYPD violated their First and Fourteenth Amendment rights through unlawful, "suspicionless" surveillance and sought an injunction to prevent further surveillance. The Plaintiffs sought to prove discriminatory intent in one or two of the ways identified in Brown: (1) an express classification theory—by showing that "the NYPD expressly classified Muslims by adopting a policy of singling them out for heightened policy scrutiny"; or (2) a discriminatory application theory—"to the extent that Respondents claim they had a legitimate law enforcement interest in  Plaintiffs, . . . by showing that [Plaintiffs] were subject to NYPD investigations of unequal and unwarranted scope, duration, and invasiveness as a result of their religious beliefs and activities." Brown v. City of Oneonta, 221 F.3d 329, 337 (2d Cir. 1999). The Respondent, the City of New York, filed for bifurcated discovery, and the Plaintiffs responded with a move for a preliminary injunction and for expedited discovery. The Respondent argued that the Plaintiffs failed to meet the necessary standard for justifying expedited discovery. The District Court granted the expedited motion in part, but set up a two-stage schedule for discovery.

The Plaintiffs, two Muslim prisoners, challenged prison policies that 1) failed to provide adequately nutritional ḥalāl meals, and 2) denied them the ritual end-of-Ramadan feast. The District Court found that the ḥalāl meals provided did not substantially burden the Plaintiffs' religious practice. The District Court also decided that although the denial of the ritual feast marking the end of Ramadan substantially burdened the Plaintiffs' beliefs, the prison demonstrated that this policy was the least restrictive means of achieving the government's interest in security.

The Plaintiff Kajauna Kenyatta Irvin named James A. Yates (warden), R. Fisher Jr. (associate warden), P.D. Brazelton (associate warden), K.R. Nash (correctional captain), M.C. Davis (associate warden), Dana B. Allen (correctional captain), A. Walker (correctional captain), Wendy K. Myers (community partnership manager), James D. Bennett (correctional lieutenant), S. Lantz (correctional lieutenant), E. McBride (correctional sergeant), D. McGee (protestant chaplain), E. Guthery (correctional officer), and Does 1-30 (PVSP correctional staff members) as the Respondents in this lawsuit, alleging that these individuals 1) forced Muslim prisoners to conduct their religious services outside; 2) failed to provide dietary accommodations for religious celebrations; 3) suspended purchase orders for religious oils; and 4) failed to hire a replacement Muslim chaplain. The District Court determined that the Plaintiff's complaint stated cognizable claims against Respondents McBride, Davis, Yates, Myers, Bennett, Allen, Nash, Walker, Brazelton, Guthery, McGee, and Does 1-30 under 42 U.S.C. § 1983 for the violation of the Plaintiff's rights under the First Amendment and under RLUIPA. The District Court provided the Plaintiff with the opportunity to file an amended complaint curing the deficiencies identified by the District Court in regard to the remaining Respondents.

The Plaintiff, Christopher B. Scott, brought suit against Dekalb County prison officials. The Plaintiff claimed that the Respondents violated his First Amendment constitutional rights by 1) not providing a Muslim chaplain; 2) not allowing Muslim prisoners to wear a kufi; 3) failing to provide a secure and private place to pray five times a day; and 4) not providing a special meal at the end of Ramadan. The Respondents sought summary judgment on the issue of exhaustion, claiming that the plaintiff had not exhausted the administrative remedies necessary to bring suit. The Magistrate Court recommended that the Respondents' motion for summary judgment be granted on the Plaintiff's claims concerning the wearing of a kufi and concerning the celebration of an end-of-Ramadan meal. Summary judgment for all other claims was denied.

The Plaintiff Akeem Muhammad, an inmate in the Florida penal system, filed suit against the Respondents (prison officials Marvin Davis, Alex Taylor, and R. Graham; the Food Service Administrator of the Fla. Dept. of Corrections; and the Assistant Warden and Warden of Florida State Prison) for their refusal to provide him with a daily pre-fasting meal. The District Court determined that the plaintiff could not sue individual Respondents for monetary damages under RLUIPA. The District Court also determined that the Respondents failed to demonstrate that the policy of refusing to provide Muslim prisoners with a pre-twilight meal during Ramadan is the least restrictive means of achieving a compelling governmental interest. Therefore, the District Court denied the Respondents' Motion for Summary Judgment on the RLUIPA claim.

The Plaintiff Amir Shabazz challenged the Pleasant Valley State Prison for their policy of denying Muslim inmates ḥalāl meals for breakfast, lunch, and dinner. The Plaintiff contended that Muslim inmates were denied ḥalāl meat, instead forcing them to eat vegetarian meal options. The Plaintiff argued that this constituted religious discrimination under RLUIPA and the Fourteenth Amendment, since Jewish inmates were provided with kosher options and therefore were not forced to similarly eat the vegetarian meal options. The Plaintiff claimed that this treatment constituted cruel and unusual punishment. The District Court found that the facts put forth by the plaintiff were "vague and inconsistent," and therefore that the Plaintiff failed to state any cognizable claim against the Respondent. 

New York University, School of Law

This course will provide an overview of the theoretical doctrines that give rise to Islamic finance and an introduction to its contemporary practice in various market contexts. We will begin with the religious impulse that gives rise to Islamic finance, including, different Islamic critiques of conventional finance and why Islamic finance is claimed to be a superior model. We will then turn to classical Islamic commercial law, and study the two principle classical doctrines of Islamic commercial law that seem to mandate the creation of alternative financing models, ribā (often translated, incorrectly, to “usury”) and gharar (often translated, incorrectly, as “speculation”). We will also cover the basic building blocks of Islamic commercial law, studying rules governing sales, leases, loans, pledges and other fundamental commercial law relationships as well as Islamic rules governing business organizations such as general and limited partnerships.

After completing an overview of historical doctrines, we will turn to how these doctrines were modernized to produce a “modern” Islamic commercial law, something that enabled the rise of contemporary Islamic finance. We will consider a broad range of Islamic financial contracts across various markets, including, consumer banking and finance, Islamic deposit taking banks, Islamic corporate finance (e.g., sukuk, sometimes called “Islamic bonds”) and Islamic derivatives. We will then consider the legal structure undergirding Islamic finance and use it as an example of the advantages/disadvantages of public ordering versus private ordering. The course will conclude with different critiques of Islamic finance.

The plaintiff, Wafaa Elwakil, brought this action against her former employer, Target Media Partners, claiming a violation of her rights pursuant to Title VII of the Civil Rights Act. The plaintiff claimed that the company subjected her to discriminatory treatment because of her race, religion, and ethnicity; created a hostile work environment; and unlawfully retaliated against her for filing a complaint with the Kenner Police Department. The company filed a motion to dismiss. The District Court dismissed the plaintiff's claims for Title VII discrimination, hostile work environment, and retaliation because the court found that the evidence indicated that the plaintiff did not engage in a "protected activity" for the purposes of her Title VII claim.

The plaintiff, Dominic Ali, a Muslim inmate at the Northern New Hampshire Correctional Facility, sued several prison officials for allegedly violating his rights under the First and Fourteenth Amendments, the Religious Land Use and Institutionalized Persons Act (RLUIPA), and the state's constitution. The plaintiff alleged that the prison failed to provide jumu'a (Friday prayer) services for Muslim inmates, failed to ensure that he was provided with healthy food during Ramadan (the Islamic month of fasting), and denied him the ability to observe Ramadan by removing his name from the prison's internal Ramadan fasting list. The defendants filed a motion for summary judgment, arguing that the plaintiff's claims should be dismissed because he did not exhaust his administrative remedies before bringing suit. The Court agreed: it found that the plaintiff had not brought his grievances to the attention of the prison's commissioner, and therefore granted the defendants' motion.

The petitioners, Elwood "Atheem" Small and Parlie DuBose, Jr., alleged that their First, Fourth, and Fourteenth Amendment rights were violated when they were strip-searched in the presence of women and when their participation in religious holiday events was, according to prison policy, conditioned upon their signing a document that allegedly placed restrictions on their religious practice. The U.S. District Court for the Western District of Pennsylvania granted the respondent's motion to dismiss the claim. The petitioners appealed. The Appellate Court affirmed the District Court's dismissal. The Appellate Court held that the Ramadan policy was reasonably related to legitimate penological interests. The Appellate Court also determined that the practice of strip-searching the petitioners in a group of inmates in the presence of female staff members did not violate the petitioners' Fourth Amendment rights, because exigent circumstances existed that necessitated the search.

The plaintiff, Regina Z. Muhammad, filed a lawsuit against her former employer, Westinghouse Electric Company LLC, asserting claims of religious and sexual harassment, religious-based disparate treatment, and retaliation under Title VII. The plaintiff contended that after her supervisor discovered she was Muslim, he made a number of discriminatory comments, and then certified other employees with whom the plaintiff had been co-trained, but not the plaintiff. The respondent subsequently filed a motion to dismiss. The District Court denied the respondent's motion to dismiss, finding that the plaintiff could prove that her lack of training, which ultimately resulted in her termination, had a significant detrimental effect on her employment.

The plaintiff, Raymond Miller, brought this action pursuant to 42 U.S.C. § 1983, alleging that the defendants, employees at the St. Lawrence County Correctional Facility (New York), violated his free exercise rights under the First Amendment by restricting his ability to practice Islam. The plaintiff alleged that the defendants only allowed him to wear his kufi headgear when inside his cell. The District Court granted the defendants' motion for summary judgment, determining that the defendants' policies were not irrational or unreasonable, and that the plaintiff had failed to demonstrate "that a more reasonable accommodation could have been made."

The plaintiffs, a group of inmates held at the Massachusetts Correctional Institute in Concord, filed suit against Massachusetts prison officials for alleged violations of their rights under the First and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act (RLUIPA). The plaintiffs alleged that the prison officials violated these rights by refusing to provide separate accommodations for adherents of the Nation of Islam, whose practices (according to one of the plaintiffs) are "distinctly different" from those of Sunnī Islam. The magistrate judge recommended that the defendants' motion to dismiss be allowed because the plaintiffs had not yet exhausted their administrative remedies within the prison system.

The plaintiff, Dennis Balk, a former professor at the New York Institute of Technology (NYIT) in Bahrain, brought this suit against the New York Institute of Technology after he was fired. Balk alleged that he was fired from his position after a daily Bahrain newspaper, Al-Ayam, published an article stating that he had posted to his class website a controversial cartoon depicting the Prophet Muhammad in rags. Balk brought this claim, which alleged discrimination based on race, religion, and national origin in violation of Title VII. The plaintiff also brought a motion to compel the deposition of Dr. Mohammed Hussein, the Executive Director of the Middle East for NYIT. The District Court determined that Dr. Hussein's deposition was necessary in the "interest of justice" within the meaning of the Walsh Act because of his alleged involvement in the plaintiff's firing. The District Court additionally found that given Dr. Hussein's periodic travel to the US, it was not unreasonable to compel Dr. Hussein to appear.

The plaintiff, Remon Shields, a prisoner serving a life sentence without parole, brought this action against the California Department of Corrections and Rehabilitation, alleging that his religion requires those who want to marry to get married and consummate their relationship, but his request for non-overnight "family visiting" with his wife were denied. The prison contended that there is a policy stating that those who are serving a life without parole sentence are ineligible for the family visiting program. The respondent filed a motion to dismiss. The District Court granted the respondent's motion to dismiss, determining that there was no fundamental right to conjugal visits, and that the plaintiff had not demonstrated that the prison regulation prohibiting conjugal visits for life-without-parole prisoners was not rationally related to a valid penological interest.

The plaintiff, Michael Mootry, sued prison officials for implementing a policy that he claimed constituted a violation of his First Amendment rights. The policy banned inmate ministers from leading religious services without the direct supervision of a hired chaplain or volunteer. As a result of this policy, for two years, Muslim inmates were not accommodated with a hired chaplain to supervise jumu'a (Friday prayer) services. The Court denied the defendants' motion to dismiss because it found that the defendants knew about the plaintiff being prevented from participating in the prayer services, that this was an ongoing issue, and that they did nothing to correct the situation.

Phillip Jean-Laurent brought an action against South Carolina prison officials for allegedly violating his First Amendment right to the free exercise of his Islamic religious tenets and the Eighth Amendment. Specifically, the plaintiff claimed that the respondents prevented his attendance at Islamic religious services during Ramadan as retaliation for him using the law library, and deprived him of evening and morning meals required by Muslim religious exercises during Ramadan, in preparation for fasting during daylight hours. The District Court found that the respondents properly answered the interrogatories as to the policy of forbidding the plaintiff to attend prayer services, but that the respondents did not properly answer questions in document requests regarding the plaintiff's and other Muslim prisoners’ ability to secure Ramadan morning meals.

The plaintiff, Kiaza Loccenitt, a Muslim inmate in the custody of the New York City Department of Correction, sued New York City and several prison officials for allegedly violating his civil rights by denying him ḥalāl meals and by denying him and other Muslim inmates in his unit the services of an imām (Muslim chaplain). The plaintiff alleged violations of his rights under the First Amendment of the U.S. Constitution, pursuant to 42 U.S.C. § 1983 and the Religious Land Use and Institutionalized Persons Act of 2000, as well as New York Corrections Law § 610. In response to the defendants' motion for summary judgment, the Court dismissed the plaintiff's claims against some of the prison officials (who were not directly involved in the alleged violations or the creation of policies that led to the alleged violations), but allowed the plaintiff to file an amended complaint to add factual details to his allegation about being denied ḥalāl meals, and about "the impact of that denial on the practice of his religion."

The plaintiff, Tracey Taylor, a pretrial detainee in the Cook County Department of Corrections (Illinois), brought an action, pursuant to 42 U.S.C. § 1983, against the respondents Cook County and Sheriff Thomas Dart for alleged violations of his civil rights in denying him access to Islamic prayer services and by failing to serve ḥalāl meat (prepared in accordance with Islamic law). The respondents moved for summary judgment after alleging that Taylor failed to exhaust his administrative remedies and failed to raise a genuine issue of material fact as to whether they violated his constitutional rights. The Court granted summary judgment for the respondents, determining that the denial of Islamic prayer services was related to a legitimate penological interest, and that the prison had adequately provided the plaintiff with sufficiently nutritious Islamic meals, even though they were vegetarian/vegan.

Plaintiff Leo Pittman-Bey, a Muslim inmate, sued Texas prison officials for allegedly violating the Religious Land Use and Institutionalized Persons Act and his constitutional right to free exercise of religion under the First Amendment by denying him after-sunset meals during the Islamic holy month of Ramadan. Previous prison regulations allowed practicing Muslim inmates to receive after-sunset meals during Ramadan, but only if they had attended jumuʿa (Friday prayer) services in the 60 days prior to Ramadan or had received a special exception from the Muslim chaplain. Pittman-Bey did not attend the services because, as an adherent of the Ḥanafī school of Sunnī Islam, he said he believed that jumuʿa services are not proper if conducted in nonpublic settings like prisons. The District Court granted summary judgment for the defendants, determining that denying Ramadan meals in accordance with the jumuʿa attendance policy did not violate the First Amendment.

Plaintiff Dorian Davis challenged the Kern Valley State Prison policy that prohibited Muslim prisoners from purchasing and possessing prayer oils in their cells. The prison officials, however, claimed that a compelling governmental interest made their policy the least restrictive means of ensuring prison safety. The District Court agreed with them, determining that the prison did not violate the plaintiff's First Amendment rights because the Muslim chaplain had previously provided contraband to prisoners; in addition, it found that RLUIPA rights were not violated because the prison had to cancel Friday prayer services until another Muslim chaplain could be hired.

The plaintiffs, two Muslim prisoners, sued state and prison officials for failing to provide Muslim inmates with ḥalāl meat options while incarcerated. The defendants claimed that inmates in the custody of the state are not entitled, under either the First Amendment or RLUIPA, to a diet that includes ritually-slaughtered meat. The defendants also requested summary judgment because they claimed that Wells-Bey did not have an allergy to eggs that inhibited his ability to eat a lacto-ovo diet as a substitute for meat. The Court determined that the defendant was not entitled to summary judgment because the plaintiff claimed he had an egg allergy and therefore could not subsist off the vegetarian meal plan; however, the Court allowed the defendants to refile their motion if they were able to obtain more information about the plaintiff's "alleged allergy."

Petitioner Tyrone Walker alleged that the prison violated his civil rights when it refused to provide him with the opportunity to participate in jumu'ah (Friday prayer) services when he was confined to the SHU. The District Court determined that the Respondent did not violate the Petitioner's rights under RLUIPA, as the Respondent's decision to deny the requests for access to Friday prayer services through closed-circuit television or through an audio feed was reasonably related to articulable, legitimate penological interests, which included the safety and the cost of installing the necessary equipment.

The plaintiff, Sefidkar Janali, a Shi'a Muslim, claimed that he should be allowed to attend a worship service apart from Sunni Muslims. The plaintiff alleged that the prison violated his First Amendment rights and RLUIPA because Muslims are not allowed different worship times, while other denominations have separate times. The plaintiff also alleged that he should be provided a ḥalāl diet (upon entering the prison, he was given the choice of a regular meal, vegetarian meal, or Jewish Kosher meals). The District Court found that the prison officials did not violate the plaintiff's First Amendment or RLUIPA rights because there were legitimate security and administrative concerns with offering separate Shi'a and Sunni services. The District Court similarly found that the meal options provided for Muslim inmates was adequate because they were lawful options for Muslims. The District Court therefore granted summary judgment for the respondents.

The plaintiff, state prisoner Horace Crump, filed suit against a Michigan Department of Corrections chaplain, David Leslie. The plaintiff alleged that he was barred from attending Friday prayer (jumu'a) services in retaliation for informing Muslim prisoners that the prison's suspension of Islamic religious services was unconstitutional. The respondent moved for summary judgment. The District Court granted summary judgment for the respondent, finding that the plaintiff failed to adequately state his need to attend these services to the prison.

Plaintiff Peter McDaniels sued various prison officials, alleging that they intentionally failed to provide him with pre-sunrise meals during Ramadan and with an Eid al-Fitr meal at the conclusion of Ramadan, in violation of his First Amendment rights to free exercise of religion. The Plaintiff also contended that the lack of provision of ḥalāl meat and deprivation of an Arabic Qurʾān for nine months were discriminatory violations of his rights. The Respondents moved for summary judgment. The District Court granted the Respondents' request for summary judgment on the Ramadan meals issue, stating that the Plaintiff failed to show that such failures to provide a meal on isolated incidents imposed a significant restriction on his religious practice. However, the District Court decided that the Respondents did not meet their burden of demonstrating that the religious diet policy furthers a compelling government interest and is the least restrictive means of furthering that compelling interest. The District Court dismissed the plaintiff's claim that the Respondents deprived the Plaintiff of his rights by not allowing him access to a Qurʾān, finding that the Respondents were not required to provide the Plaintiff with an Arabic Qurʾān or dates to be used in his devotional practice, given the absence of any showing that Respondents prevented him from obtaining such items. The Plaintiff did not seek injunctive relief, but the Court found that the individual Respondents were entitled to qualified immunity, so they could not be held liable for personal damages under RLUIPA.

Plaintiff Tabari Strong, a Muslim prisoner in Beeville, Texas, filed a lawsuit alleging that the prison's grooming policy requiring all inmates to be clean-shaven violated his statutory rights under RLUIPA. He also claimed that the policy violated his right to exercise his religion under the First Amendment, and that enforcement of the policy violated his right to equal protection under the Fourteenth Amendment. The plaintiff filed a motion for summary judgment, claiming that he is entitled to a declaratory judgment. The District Court refused to grant the plaintiff's request for injunctive relief as an "extraordinary remedy," but maintained that it would be contrary to justice not to grant the relief requested by the plaintiff to have a quarter-inch beard.

Plaintiff Marlo Thomas, incarcerated at the Ely State Prison (ESP), brought this action against former ESP Warden E.K. McDaniel, former ESP Associate Warden Renee Baker, and former ESP Associate Warden Debra Brooks, for an alleged violation of his First and Fourteenth Amendment rights. The Plaintiff claimed that he was placed in administrative segregation by the Respondents because they had a personal grudge against him because he was a Muslim inmate. The Respondents filed a motion for summary judgment. The District Court found that the Plaintiff failed to submit any evidence to support several elements of his First Amendment free exercise claim and his Fourteenth Amendment claim. The District Court found that the Plaintiff produced no evidence that he sincerely believed he must engage in group worship to satisfy the tenants of his Islamic faith. Furthermore, the District Court found that the Plaintiff produced no evidence that Respondents' decision to confine him in administrative segregation was not reasonably related to the prison's legitimate penological interests, and instead found that the Plaintiff was placed in administrative segregation for safety and security reasons unrelated to religious discrimination.

Plaintiff Larry William Cortinas brought this action against the California prison system, alleging a violation of his Eighth Amendment and Fourteenth Amendment rights. The Plaintiff alleged that medical staff at the prison refused him treatment and medication for his rheumatoid arthritis and hepatitis C because he was Muslim. The Plaintiff filed a motion for default judgment. The District Court determined that the Plaintiff's allegations were sufficient to demonstrate that he would be entitled to relief under the Eighth Amendment and the Equal Protection Clause of the Fourteenth Amendment.

The Plaintiff, Marcus Leeotis Watts, sued the Respondents, various prison officials at the Perry Correctional Institution in South Carolina, for allegedly violating his rights under RLUIPA and the First Amendment when the prison failed to provide Muslim prisoners with ḥalāl meat. The Respondents contended that the vegetarian meal option that complied with Islamic law was adequate, and sought summary judgment. The District Court granted summary judgment for the Respondents, citing earlier case law providing that the failure to provide a ḥalāl diet containing meat did not substantially burden prisoners' exercise of religion because a Muslim prisoner is not religiously-obligated to eat meat.