Khan v. Payton

Background

Muhammad Khan, a state prisoner, sued under 42 U.S.C. § 1983 without a lawyer. The operative first amended complaint proceeded against Correctional Officers M. Payton and Healy. Khan alleged that prison staff denied him Ramadan meals at San Quentin Rehabilitation Center during June 2018. The court previously found that the complaint stated claims under the First Amendment, the Eighth Amendment, and the Due Process Clause, and also allowed state-law claims for intentional infliction of emotional distress and negligent hiring, training, or supervision.

During Ramadan, Khan was supposed to receive a package containing dinner and the next morning’s breakfast after sundown. He alleged that Payton refused to give him meals on June 11 and again told him on June 12 that he would not receive them. He alleged that Healy kept his cell door locked, blocked food another inmate had left for him, and did not provide an alternative meal. Khan testified that he missed meals for about 24 hours on June 8–9 and for about two days on June 11–12. He reported hunger pains, emotional distress, and humiliation, but did not claim a physical injury from the missed meals.

Khan did not oppose the defendants’ motion for summary judgment, despite receiving more than eight months to do so. Because his first amended complaint was verified, the court treated it as evidence opposing summary judgment to the extent it was based on personal knowledge and stated specific admissible facts.

First Amendment claim

The court held that the alleged interruption of Ramadan meals did not violate the First Amendment’s protection for religious exercise. A prisoner must show that the government substantially burdened a sincerely held religious practice. The court concluded that Khan did not show that the missing meals prevented him from practicing Islam, forced him to break his fast, or substantially pressured him to violate his beliefs. The court described the missed meals as a partial interruption over three days of a 28-day fasting period and found that the burden was minor rather than substantial.

The court therefore granted summary judgment to the defendants on the First Amendment claim. It also addressed qualified immunity, a protection that can shield government officials from damages when their conduct did not violate a clearly established right. The court found that, even if Khan had clearly shown that he was denied Ramadan meals for three days, a reasonable officer would not have been on notice that this conduct violated clearly established First Amendment law. Summary judgment based on qualified immunity was therefore granted on this claim as well.

Eighth Amendment claim

The court held that the alleged denial of Ramadan meals did not violate the Eighth Amendment’s prohibition on cruel and unusual punishment. Although adequate food is a basic human need, the court concluded that the Eighth Amendment requires adequate food, not a particular religious type of meal. It found that the evidence showed Khan could eat regular meals, including when he ate a regular meal on June 8 after becoming sick, and that he did not establish that defendants denied him access to regular food.

The court also found that missing about six meals over 28 days was not the sustained deprivation required for an Eighth Amendment claim. Khan’s hunger pains, without other physical injury or evidence of harm to his health, did not establish a sufficiently serious deprivation. The court granted summary judgment to the defendants on the Eighth Amendment claim and also found that qualified immunity independently protected them because the asserted right was not clearly established under these circumstances.

Due process claim

The court granted summary judgment to the defendants on Khan’s due process claim. It held that missing three days’ worth of Ramadan meals did not deprive him of life, liberty, or property, did not implicate an interest created by state law or regulation, and was not an atypical and significant hardship compared with ordinary prison life. The court also found that the deprivation would not inevitably affect the length of Khan’s sentence. Because there was no constitutional violation, the court did not address qualified immunity for this claim.

State-law claims

The defendants argued that Khan failed to comply with the California Government Claims Act, which requires a person seeking damages from a covered California governmental entity or employee to present a claim to the state claims board within the required time. The court found that Khan’s complaint did not allege compliance and that the undisputed evidence showed he had filed claims concerning property loss, failure to protect him from an attack, and damage to his property—not the claims in this case.

The court concluded that any new claim would be too late under the six-month deadline. It dismissed the state-law claims for failure to state a cause of action and did not reach the defendants’ other arguments concerning those claims.

Disposition

The court granted the defendants’ motion for summary judgment. The First Amendment, Eighth Amendment, and due-process claims against M. Payton and Healy were dismissed with prejudice. The state-law claims were also dismissed with prejudice for failure to comply with the California Government Claims Act. The order terminated Docket No. 72.