Price v. Annucci

Background

Trevor Price, who is incarcerated at Sing Sing Correctional Facility, filed this self-represented lawsuit under 42 U.S.C. § 1983. He alleged that Anthony Annucci, Joseph Sergeant, and two John Doe officers denied him the opportunity to attend a Jumah prayer service during Ramadan. The complaint asserted violations of the First and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act, a federal law protecting religious exercise by people confined in institutions.

The complaint originally involved 30 incarcerated people and was filed from the perspective of Byron K. Brown, identified as the lead plaintiff. The court had previously separated the individuals’ claims into separate cases and stated that each person needed to provide facts about his own experience. The complaint did not contain facts specific to Price.

Court’s analysis

The court explained the pleading standards for religious-freedom claims. A First Amendment free-exercise claim requires facts showing significant interference with a person’s religious beliefs. Under the Religious Land Use and Institutionalized Persons Act, the government generally may not substantially burden religious exercise in an institution unless it satisfies strict requirements involving a compelling governmental interest and the least restrictive means of achieving that interest.

The court did not decide whether Price’s allegations ultimately established a constitutional or statutory violation. Instead, it concluded that the complaint did not explain when Price was allegedly denied access to the service, how he was affected, or what steps he took to challenge the denial. The court directed Price to address, among other matters, whether he registered as Muslim with the Department of Corrections and Community Supervision, requested to attend the April 14, 2023 service, was denied access, filed a grievance, and previously participated in Muslim religious activities.

Disposition

The court granted Price leave to file an amended complaint within 60 days. The amended complaint must replace, rather than supplement, the original complaint and must include the facts and claims Price wants the court to consider. It must identify relevant people and defendants, describe the events and each defendant’s involvement, state the injuries, and identify the requested relief. No summons would issue at that time. The court stated that the complaint would be dismissed for failure to state a claim if Price did not timely amend and could not show good cause for the failure.

The court denied Price’s motion for appointment of counsel without prejudice to renewal at a later date because the case was at too early a stage for the court to evaluate its merits. The court deferred deciding whether to exercise supplemental jurisdiction over any state-law claims. It also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal from the order.

Judge

The order was signed by Laura Taylor Swain, Chief United States District Judge.