Allah v. Annucci

Background

Shakim Abd Allah, who was incarcerated at Great Meadow Correctional Facility when the opinion was issued, sued Anthony Annucci, Cheryl Morris, Thomas Griffin, and Jaifa Collado over religious practices at Green Haven Correctional Facility. The earlier proceedings dismissed all claims against Annucci and Morris, as well as some claims against Griffin and Collado. The remaining claims sought damages from Griffin and Collado for allegedly unequal religious accommodations and from Collado for allegedly preventing Abd Allah from attending several Shi’ite religious events in October 2015.

Abd Allah is a Shi’ite Muslim. During the relevant period, Green Haven offered one weekly Muslim service, general Muslim religious classes, and a shared Muslim fundraising account. The facility also held certain Shi’ite religious events, permitted visiting Shi’ite chaplains and inmates to lead prayers, and allowed Shi’ite inmates to attend separate Thursday evening classes. Abd Allah maintained that he needed religious services led by a Shi’ite Muslim and that the shared services and fundraising arrangements did not meet his religious needs.

In October 2015, Abd Allah was unable to attend services for Ghadir Khum, Mubahila, and the Days of Ashura because housing officers told him they had no event package or call-out listing the events. After receiving Abd Allah’s letter about the problem, Collado directed officials and the Muslim chaplain to ensure that he could attend future services. Collado was away from the facility during part of the Days of Ashura period, and Abd Allah remained unable to attend services. Abd Allah later filed a grievance requesting, among other things, separate Shi’ite services, a Shi’ite chaplain, additional classes, a separate fundraiser, and a Shi’ite clerk.

Summary-judgment standard

Summary judgment is proper when the evidence shows no genuine dispute over a fact that could affect the result and the moving party is entitled to judgment under the law. The court must generally view the evidence favorably to the party opposing the motion. Although Abd Allah did not respond to the defendants’ required statement of facts or oppose the motion, the court reviewed the record, including his deposition, while giving appropriate consideration to his self-represented status.

Missed religious events

The court held that Abd Allah did not produce evidence showing Collado’s personal involvement in the denial of access to the holiday services. Collado first learned of the problem from Abd Allah’s October 9 letter, received on October 14. She then contacted the Muslim chaplain and directed that event packages be delivered or sent to Abd Allah’s housing block. The court concluded that Collado acted promptly after learning of the problem and could not be held liable merely because other officials allegedly failed to carry out those instructions.

The court also rejected liability based on Collado’s supervisory position. Under 42 U.S.C. § 1983, a defendant generally must have personally participated in the alleged constitutional violation; a supervisor is not automatically liable for subordinates’ conduct. The court therefore granted summary judgment to Collado on Abd Allah’s claim concerning access to the holiday services.

Equal-protection claims

For the equal-protection claims, Abd Allah had to show that he was treated differently from similarly situated members of another religion and that the difference was based on religion or another impermissible reason. The court found that he failed to identify a similarly situated religious group. The evidence showed that about 14 Green Haven inmates identified as Shi’ite in October 2015, while more than 200 inmates identified as Sunni. Abd Allah also acknowledged that he did not know of another comparably small religious group that received separate services or a separate chaplain. The court therefore held that his equal-protection claims failed.

Free-exercise claims

The First Amendment protects prisoners’ ability to practice their religion, but prison policies may limit that ability when reasonably related to legitimate prison-management interests. A prisoner asserting a free-exercise claim must first show that the challenged conduct substantially burdened a sincerely held religious belief. In a § 1983 claim, the prisoner must also show that the particular defendant knew, or had reason to know, facts showing that the conduct could be unlawful.

The court held that Griffin and Collado lacked the necessary knowledge before Abd Allah filed his grievance because neither official knew that he was requesting the various accommodations. The court further found that the grievance did not clearly explain that shared services or fundraising substantially burdened his religious practice or that he required a separate Shi’ite Jummah service. The officials reasonably understood the requested accommodations to be available to the general Muslim community and believed, based on Department of Corrections and Community Supervision guidance, that those arrangements were sufficient.

The court also held that Griffin and Collado were entitled to qualified immunity. Qualified immunity protects government officials from damages when their conduct did not violate clearly established law or when a reasonable official could have believed the conduct was lawful. The court concluded that, given the limited detail in Abd Allah’s grievance, the administrative and security burdens of his requests, and the uncertainty about the constitutional requirements for a small religious group in those circumstances, any violation was not clearly established.

Disposition

Judge Kenneth M. Karas granted the defendants’ Motion for Summary Judgment, directed the Clerk to enter judgment for the defendants, and ordered the case closed.