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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.

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The plaintiff, who won a judgment in the lower court, challenged the U.S. District Court for the District of Maine’s refusal to retry an employment discrimination case in which the jury refused to award damages despite finding the defendants guilty. In the underlying case, the plaintiff had sued his employer under §1981 and Title VII, alleging religious and national-origin discrimination as well as harassment based on his race and religion in the form of a wide range of offensive actions and statements aimed at the plaintiff, including likening the plaintiff to Osama bin Laden, telling him to go back to his own country, and attempts to shove pork in his mouth (Islamic law prohibits the consumption of pork). The plaintiff argued that on a guilty finding, the jury was obliged to award damages as a matter of law. The appellate court, however, pointed to precedent rejecting this argument, and thus affirmed the lower court’s decision not to retry the case.

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. 

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.

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."

Four Muslim prisoners brought a suit against the Michigan Department of Corrections, claiming that the meals that were provided to them during the month of Ramadan provided inadequate nutritional and caloric value. According to the plaintiffs, the defendant had failed to abide by a previous court ruling requiring them to provide a certain number of calories per day. In addition, the plaintiffs claimed that neither the defendant nor the previous judge had ensured that a similar situation would not occur the following Ramadan. The plaintiffs filed an "Emergency Motion for Temporary Restraining Order, Preliminary Injunction and/or Permanent Injunction." The Court denied it as moot, since Ramadan 2013 had already concluded, and Ramadan 2014 was too far into the future to warrant immediate action.

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.

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, 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 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, 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.

Plaintiff William Welch claimed the Saginaw Correctional Facility violated his First Amendment right to free exercise of religion by providing meals that provided insufficient nutrition and calories. The appellate court agreed that Welch had demonstrated a potential violation of his constitutional rights, and affirmed the district court's earlier denial of qualified immunity to the defendants. 

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.

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.

The Plaintiffs, Michigan Department of Corrections (MDOC) prisoners Eric Dowdy, Averis X Wilson, Roger Hunt, Amira Salem, Tom Traini, Patricia L. Caruso, Dave Burnett, and Michael Martin, alleged that the Defendants, various MDOC employees, violated their rights under federal and state constitutional provisions and RLUIPA by unlawfully restricting their religious practices. Specifically, the Plaintiffs challenged the Respondents’ alleged failure to accommodate certain religious practices which they claimed must be observed during particular days and times each week. The Muslim Plaintiffs specifically challenged that the inability to attend Friday (jumuʿa) prayer services without obtaining permission to exercise a “call-out”—permission which is often denied—violated their federal and state constitutional rights. The Muslim Plaintiffs also challenged the Respondents’ alleged failure to accommodate their religious dietary restrictions and their observance of the Eid al-Fīṭr and Eid al-Aḍḥā feasts. In response to the first allegation, the Respondents claim that there is a legitimate governmental interest in prison security that would be compromised if inmates were allowed to attend prayer services. The District Court determined, however, that while a legitimate governmental interest existed, the restriction of prayer services was not the least restrictive means of protecting this compelling interest in prison security. Accordingly, the District Court did not grant summary judgment in response to the Plaintiffs’ Friday prayer claim. In response to the second allegation, the Court determined that failure to provide Muslim inmates with a ḥalāl diet substantially burdens a religious exercise, but found that a question of fact exists as to whether the Plaintiffs received such a diet.

In this case, petitioner Ray Anthony Smith, a Muslim inmate housed in a Colorado state prison, alleged a violation of his federal constitutional right to the free exercise of religion and his federal statutory right to a diet that complies with his faith. Specifically, he alleged that prison officials revoked his right to aḥalāl diet upon observing him ordering non-ḥalāl food. Petitioner Smith submitted a request for reinstatement of hisḥalāl diet through the internal prison grievance system, which was denied. Smith initiated this federal lawsuit in 2020 alleging violations of free exercise of religion under the First Amendment of the U.S. constitution and the Religious Land Use and Institutionalized Persons Act (“RLUIPA”). His complaint alleges that the Colorado Department of Corrections, Dr. Muhammad Munir Chaudry, and The Islamic Food and Nutrition Council of America (IFNCA) violated his rights by the wrongful revocation of his religious diet and mislabeling of ḥalāl food products. Upon reviewing the record, in Smith v. Crockett, U.S. Magistrate Judge Nina Y. Wang determined that the petitioner alleged actions that sufficed to make out a basic claim and recommended that government officials should not receive immunity. The Judge recommended, however, dismissal of Smith’s other allegations–including monetary damages against the government defendants for fraudulent misrepresentation of ḥalāl food products, and that the IFNCA and Dr. Chaudry be held liable for government actions.

This order implements the decision from the District Court of Colorado in Smith v. Crockett, a case in which a Muslim inmate sued Colorado state prison officials on allegations that they had violated his federal constitutional and statutory rights to free exercise of religion and to a diet that confirmed to the dictates of his faith. In this case, petitioner Ray Anthony Smith, a Muslim inmate housed in a Colorado state prison, alleged a violation of his federal constitutional right to the free exercise of religion and his federal statutory right to a diet that complies with his faith. Specifically, he alleged that prison officials revoked his right to a ḥalāl diet upon observing him ordering non-ḥalāl food. Petitioner Smith submitted a request for reinstatement of his ḥalāl diet through the internal prison grievance system, which was denied. Smith initiated this federal lawsuit in 2020 alleging violations of free exercise of religion under the First Amendment of the U.S. constitution and the Religious Land Use and Institutionalized Persons Act (“RLUIPA”). His complaint alleges that the Colorado Department of Corrections, Dr. Muhammad Munir Chaudry, and The Islamic Food and Nutrition Council of America (IFNCA) violated his rights by the wrongful revocation of his religious diet and mislabeling of ḥalāl food products. Upon review, U.S. District Judge William J. Martinez, who adopted the recommendation of U.S. Magistrate Judge Nina Y. Wang that government officials not receive immunity but that the court dismiss Smith’s other allegations–including monetary damages against the government defendants for fraudulent misrepresentation of ḥalāl food products, and that the IFNCA and Dr. Chaudry be held liable for government actions. This order implements that recommendation and decision adopted by the district court.