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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."

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 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 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.

To fund construction for a new building without violating Islamic law's prohibition against interest, the Islamic Center of Nashville (ICN) entered into an ijāra agreement with Devon Bank; the bank created a subsidiary for the purpose of the ijāraagreement. Under the agreement, Devon Bank had legal ownership of the building's title until ICN could fully purchase the building. After ICN paid the amount for the building's construction, ownership was transferred to ICN from Devon Bank. ICN applied for a property tax exemption, including for the time period in which Devon Bank held the title for the building. The state of Tennessee denied ICN the exemption for the period in which Devon owned the building, but granted it for the time after. ICN appealed that decision. 

Plaintiff Shawn Sharp, an inmate in the custody of the Pennsylvania Department of Corrections (DOC), brought this civil rights action pursuant to the First Amendment, the Fourteenth Amendment, and RLUIPA, claiming that two prison facilities unlawfully denied his request to accommodate his particular religious group. The plaintiff claimed that the Sunni Muslim services offered at the DOC did not allow him free exercise of his religion, since he is a member of the so-called Habashi sect of Islam, which has ideological differences from the prison’s recognized Sunni group. The prison’s Muslim chaplain disagreed, stating that if Sharp was a Sunni Muslim, as he claimed to be, then there was no reason why Sharp could not attend the already-provided services of Sunni Muslims. The Court decided in favor of the Defendants, determining that the DOC successfully presented a qualified immunity defense, and that the plaintiff’s request had no rational connection to any legitimate penological interest.

This case was brought on appeal from the U.S. District Court for the Western District of Virginia, which granted summary judgment in favor of the defendants, prison officials (Warden Jack Lee, Assistant Warden Gene Shinault, and Correctional Officer K. Lester). Petitioner Leroy Lovelace was removed from a “pass list” (which gives inmates access to Ramadan prayer services and special meals) after prison officials claimed that he broke his fast by eating during the day. Lovelace argued that his removal was due to his complaints about expired food, and was thus in violation of his First Amendment right to free exercise of religion, the Fourteenth Amendment right to due process, and the requirements of Section 3 of the Religious Land Use and Institutionalized Persons Act (RLUIPA) (protecting prisoners from having their religious practices substantially burdened, without a compelling government interest). Section 3 of RLIUPA states that “No government shall impose a substantial burden on the religious exercise of a person residing in or confined to an institution, as defined in section 1997 of this title, even if the burden results from a rule of general applicability, unless the government demonstrates that imposition of the burden on that person--is in furtherance of a compelling governmental interest; and is the least restrictive means of furthering that compelling governmental interest.” 42 U.S.C.A. §2000cc-1(a). The Court vacated the grant of summary judgment in favor of Officer Lester, the prison official who reported the alleged fast breaking, as well as against Warden Lee, who was in charge of overseeing the prison, concluding that both officials played direct roles in the incident. The Court remanded the case to the district court to determine whether the plaintiff had made out a valid due process claim, and the Court affirmed the remainder of the district court’s grant of summary judgment in favor of the defendants.

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.

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.

Plaintiff Hilton Karriem Mincy, a Muslim prisoner at the Lycoming County Prison, brought this suit against the Respondents – the county prison, the prison warden and other prison officials – alleging that the prison’s inadequate food service during Ramadan, which included no hot meals at the end of the day and evening meals of insufficient caloric content to compensate for the absence of a daytime meal, constituted a failure to accommodate his religious beliefs and a violation of the RLUIPA. The U.S. District Court for the Middle District of Pennsylvania entered summary judgment in favor of the Respondents, and the Plaintiff appealed. The Court of Appeals affirmed the judgment of the District Court. The Court of Appeals determined that the Plaintiff identified no official policy promulgated by the prison administration which violated his constitutional rights, and there was no evidence to suggest that any named Respondent played a direct role or had any personal involvement in the preparation or storage of food.

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.

Plaintiff Charles Glenn, an inmate at the New Hampshire Department of Corrections (DOC) filed suit against the Respondents, various DOC prison officials, for alleged violations of his rights to free exercise [of his ability to exercise Islamic ritual law] under the First Amendment and RLUIPA. Specifically, the Plaintiff – a practicing Muslim – argued that there had been no Friday prayer (jumuʿa) services at the New Hampshire State Prison for the past three years and that he had no access to an Imam (a Muslim prayer leader), a Qur’an, or other Islamic literature, which placed constraints on his ability to practice Islam [specifically, it's ritual law aspects]. In conducting a Preliminary Review, the Court applied the four-part test for examining the constitutionality of a regulation that restricts an inmate’s First Amendment free exercise of religion found in Turner v. Safley, 482 U.S. 78, 89-90 (1987). The Court assessed the four Turner factors -- (1) whether there is a valid, rational connection between the regulation and the legitimate government interest put forward to justify it; (2) whether alternative means to exercise the right exist; (3) what impact accommodating the right will have on prison resources; and (4) whether there was an absence of alternatives to the prison regulation. The Court found that the prison’s policy of denying Friday Prayer (jumuʿa) services, which are a central and essential element of religious practice, impinged on the Plaintiff’s First Amendment right to exercise his religion.

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.

In this decision, U.S. District Judge William J. Martinez adopts the recommendation of U.S. Magistrate Judge Nina Y. Wang 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 of the record, Judge Martinez agreed with Judge Wang’s recommendation that the government officials were not entitled to immunity, as petitioner Ray Anthony Smith had made sufficient allegations to make out a prima facie claim. Also following Judge Wang’s recommendations, Judge Martinez dismissed 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.