Williams v. Conway

Background

Mali W. Williams, an inmate at Salinas Valley State Prison, filed this civil-rights action without a lawyer under 42 U.S.C. § 1983. The court had previously dismissed his original complaint while allowing him to amend it. This order reviewed the amended complaint under 28 U.S.C. § 1915A, which requires federal courts to screen prisoner complaints against government entities or employees and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant.

Williams described two groups of allegations. First, he alleged that during the 2017 Ramadan month, the daily meal sack provided to fasting Muslim inmates lacked a main breakfast course. He alleged that supervising correctional cook B. Mustafa, food manager R. Conway, and assistant correctional food manager J. Castillo knowingly failed to provide the main course for 30 days, while inmates who were not observing Ramadan received breakfast meals with a main course. He claimed violations of religious freedom, equal protection, and the Eighth Amendment right to adequate food.

Second, Williams alleged that from about late March 2017 through June 2018 he was not given the same opportunity as members of other religions to attend religious services. He alleged that, because there was no assigned Muslim religious leader or chaplain, he could attend Jumu’ah prayer services in the chapel only on Fridays during even-numbered weeks. On odd-numbered weeks, he had to use an outdoor area that he said was unsuitable because of conditions including bird droppings, dried pepper spray, noise, holes, and possible interruptions. He alleged that community resource manager Carole Hernandez and warden T. Foss failed to approve an adequate alternative, violating his religious-freedom and equal-protection rights.

Claims the Court Found Cognizable

The court held that the amended complaint stated claims against Mustafa, Conway, and Castillo under the First Amendment’s Free Exercise Clause, the Religious Land Use and Institutionalized Persons Act, and the Fourteenth Amendment’s Equal Protection Clause based on the missing Ramadan breakfast course. It also held that the allegations stated an Eighth Amendment claim for denial of adequate food.

The court separately held that the amended complaint stated claims against Hernandez and Foss under the First Amendment’s Free Exercise Clause and the Religious Land Use and Institutionalized Persons Act based on the alleged lack of an adequate space for Jumu’ah services on alternate Fridays. It also found an equal-protection claim against those defendants because Williams alleged that other religions had adequate space for services every week.

The court explained that a religious-freedom claim requires an unjustified burden on religious practice, while the religious-land-use statute requires a substantial burden on religious exercise unless the government satisfies a demanding justification test. For an equal-protection claim, the plaintiff must allege intentional discrimination based on membership in a protected class. For an Eighth Amendment food claim, the alleged deprivation must be objectively serious, and officials must have deliberately disregarded a known risk to the inmate’s health or safety. At the screening stage, the court concluded that Williams’s allegations met the requirements to proceed on these claims.

Claims and Defendants Dismissed

The court concluded that the people who denied Williams’s inmate appeals about the Ramadan meals could not be held liable on the allegations presented. The court explained that the appeals were filed after Ramadan had ended, so the officials responding to the appeals could not have prevented or stopped the alleged food deprivation. The court also stated that there is no due-process right to have an inmate appeal processed or decided correctly.

The order stated that all other claims and defendants were dismissed. It did not add a “with prejudice” or “without prejudice” qualifier to that statement.

Order

The court directed the Clerk to issue summonses and the United States Marshal to serve B. Mustafa, R. Conway, J. Castillo, Carole Hernandez, and T. Foss without requiring Williams to prepay service fees. It set a schedule for defendants’ summary-judgment or other dispositive motions, Williams’s opposition, and any reply. It also stated that the parties could conduct discovery without another order under the cited rules.

The court granted Williams’s request for a copy of the extension-of-time request he had mistakenly filed in the case and directed the Clerk to mail him copies of that document and its envelope. Judge Edward M. Chen signed the order on September 18, 2020. This was a screening and service order, not a final decision on the truth of the allegations or the ultimate merits of the surviving claims.