Williams v. Conway

Background

Mali W. Williams, a Muslim inmate at Salinas Valley State Prison, filed this civil-rights action without a lawyer under 42 U.S.C. § 1983. The court reviewed the complaint under the prisoner-screening statute, 28 U.S.C. § 1915A.

Williams described two groups of allegations:

1. Ramadan meal sacks. Williams alleged that during Ramadan in 2017, prisoners observing a daylight fast were supposed to receive a breakfast-and-lunch sack containing two complete meals each day. He alleged that his sack lacked a breakfast main course, such as hard-boiled eggs, tuna, or pastries. He claimed that the meals deprived him of adequate food and interfered with his religious freedom. He named R. Conway, Castillo, Mustafa, and Binkele, but described their responsibility by saying they had “allowed a process to be displayed against” him.

The complaint attachments indicated that the prison used an April 27, 2017 memorandum listing the meal-sack items and stating that they provided 1,674 calories, compared with 1,582 calories identified in the food-service handbook. The court noted that the handbook’s sample Ramadan meals did not require those particular foods at every prison. Williams also alleged that his meals differed from those served to other inmates.

2. Jumuah prayer services. Williams alleged that from about February or March 2017 until about June or July 2018, no Muslim chaplain was assigned to his prison yard. As a result, regular Friday prayer services were available every other week. On other weeks, services depended on volunteers; one correctional cook volunteered three times in a year. Williams alleged that the alternative outdoor religious area was loud, dirty, and next to visible bathrooms, and that he should have been allowed to use the chapel. He named T. Foss and Carole Hernandez, but said only that events were not properly handled and that this led to the denial of his access to services.

Court’s analysis

The court held that the meal-sack claims did not adequately connect any defendant to an alleged constitutional violation. It explained that merely responding to a grievance about a completed past violation does not create liability for that violation. Because Ramadan had ended before Williams filed his grievance, an official responding to the grievance could not have prevented or stopped the alleged meal problem.

The court also found that Williams had not provided enough facts for an Eighth Amendment claim based on inadequate food. He needed to allege an objectively serious deprivation and deliberate indifference, meaning that an official knowingly disregarded a serious risk to his health or safety. The court was unsure whether Williams was alleging that he received inadequate nutrition or merely that he did not receive particular foods. If he received the items listed in the prison memorandum, or comparable items, he needed to explain why the meals were not nutritionally adequate.

The court found that Williams had not explained how the meal sacks substantially burdened his religious exercise under the First Amendment or the Religious Land Use and Institutionalized Persons Act, a federal law protecting religious exercise in institutions. His equal-protection theory also lacked sufficient facts showing that officials intentionally treated him differently because of his religion. The court noted that the different meal items might instead have resulted from food-safety concerns involving food left unrefrigerated for several hours.

As to the prayer-service allegations, the court found that Williams had not adequately linked any defendant to interference with his religious-freedom or equal-protection rights. The allegation that events were not properly handled was too vague, and the allegation about Hernandez’s statement concerning a possible volunteer did not by itself state a claim.

Disposition

The court dismissed the complaint for failure to state a claim upon which relief could be granted. It granted leave to amend so Williams could try to allege one or more viable claims. The amended complaint had to be complete, identify each defendant and that defendant’s alleged conduct, use the case caption and civil case number, and be filed by February 17, 2020. The court stated that failure to file by that deadline would result in dismissal of the action.