Amaker v. Lee

Background

Anthony D. Amaker, proceeding without a lawyer, sued multiple individuals and entities, including the New York State Department of Corrections and Community Supervision and Corrections Officers Michael Burzo, Eric Hoiston, and Ryan Lieberman. He asserted claims under the Religious Land Use and Institutionalized Persons Act and 42 U.S.C. § 1983. After earlier rulings dismissed his other claims, the remaining claims were First Amendment Free Exercise Clause claims against Burzo, Hoiston, and Lieberman.

The remaining claims arose during Ramadan in July 2013 at Green Haven Correctional Facility. Amaker worked as a server and prepared pre-dawn meal bags for Muslim inmates. After a kitchen employee accused him of taking or failing to dispose of food, Lieberman told him he could no longer work in the kitchen or mess hall. The next day, Amaker returned to distribute meal bags. After he was ordered to stop, a disturbance occurred, and he received a misbehavior report. He was then ordered to return to his cell and was kept there during the relevant period. Amaker alleged that this prevented him from participating in a communal meal and breaking his fast with other inmates.

The defendants moved for summary judgment under Federal Rule of Civil Procedure 56. Amaker did not oppose the motion despite receiving multiple extensions.

Court’s analysis

A summary-judgment motion is granted when the record shows no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment under the law. For a First Amendment Free Exercise claim, the prisoner must show a sincere religious belief that was substantially burdened and that the challenged conduct was not reasonably related to a legitimate prison-management interest.

The court first ruled that Burzo and Hoiston lacked the personal involvement required for individual liability under Section 1983. The court found that neither officer was present during the kitchen accusation or the mess-hall disturbance, neither was involved in issuing the misbehavior report, and merely escorting Amaker back to his cell was insufficient to establish direct participation in a constitutional violation. The claims against Burzo and Hoiston therefore could not proceed.

The court found a material factual dispute about Lieberman’s direct involvement but nevertheless ruled for him on the merits. The court determined that directing Amaker to return to his cell was reasonably related to the legitimate prison interest in maintaining security and order. Amaker received a meal, although he said it did not include a pre-dawn meal bag, and he was prevented from joining the communal meal on only one day of Ramadan. The court concluded that this did not substantially burden his religious rights. Because it found no First Amendment violation, it did not address qualified immunity.

Disposition

The court granted the defendants’ motion for summary judgment on Amaker’s First Amendment claim. It dismissed the remaining claim with prejudice, directed the Clerk of Court to enter judgment for the defendants, and closed the case.