Ramos v. Annucci

Background

Ivan T. Ramos, who was incarcerated at Sing Sing Correctional Facility, brought a self-represented lawsuit under 42 U.S.C. § 1983 against Anthony Annucci, Joseph Sergeant, and two John Doe officers. He alleged violations of the First and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act based on the denial of access to a Jumah prayer service during Ramadan. The court had previously allowed him to proceed without prepaying filing fees.

The original complaint had been filed by 30 incarcerated people and was written from the perspective of Byron K. Brown, the lead plaintiff. The court had severed the prisoners’ claims into separate cases and required each person to provide facts about his own experience. Because the complaint did not contain facts specific to Ramos, it did not explain when Ramos was denied the service, how he was affected, or what steps he took to challenge the denial.

Court’s analysis

The court explained that a First Amendment religious-exercise claim requires facts showing that the defendants significantly interfered with the plaintiff’s religious beliefs. Under the Religious Land Use and Institutionalized Persons Act, the government generally may not substantially burden an incarcerated person’s religious exercise unless the burden furthers a compelling governmental interest through the least restrictive means.

The court did not determine whether Ramos’s allegations ultimately established a constitutional or statutory violation. Instead, it directed him to provide facts addressing whether he registered as a Muslim with the Department of Corrections and Community Supervision, requested to attend the April 14, 2023 Jumah service, was denied attendance, filed a grievance, and previously participated in Muslim religious services, holidays, and related events.

Rulings

The court granted Ramos leave to file an amended complaint within 60 days. The amended complaint must replace, rather than supplement, the original complaint and must identify the relevant people, describe what each defendant did or failed to do, state when and where the events occurred, describe any injuries, and identify the relief sought. The court warned that the complaint will be dismissed for failure to state a claim if Ramos does not timely comply and cannot show good cause.

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