Williams v. Annucci

Background

Teddy Williams, who is incarcerated at Sing Sing Correctional Facility, filed this self-represented civil-rights action under 42 U.S.C. § 1983. He alleges that Anthony Annucci, Joseph Sergeant, and two unidentified officers denied him the opportunity to attend a Jumah prayer service during Ramadan. He asserts claims under 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 was filed by 30 incarcerated people seeking to proceed as a class. The court had separated their claims into individual cases and explained that each person needed to provide facts about that person’s own experience. Williams’s complaint, however, was written from the perspective of another plaintiff and did not allege facts specific to Williams.

Court’s analysis

The court explained that prisoner complaints seeking relief from government officials must be screened. A complaint may be dismissed if it is frivolous, malicious, fails to state a claim, seeks money from an immune defendant, or falls outside the court’s jurisdiction. Although courts read self-represented pleadings liberally, the complaint must still provide enough factual detail to make a claim plausible.

The court described the standards for Williams’s potential religious-freedom claims. Under the First Amendment’s Free Exercise Clause, a plaintiff must allege facts showing that 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 a confined person’s religious exercise unless the burden serves a compelling governmental interest through the least restrictive means.

The court did not determine whether Williams could satisfy either standard. Instead, it concluded that the complaint lacked facts about Williams himself. The court directed him to address, among other things, whether he registered as Muslim with the Department of Corrections and Community Supervision, requested to attend the April 14, 2023 Jumah service, was denied access, filed a grievance, and previously participated in Muslim religious practices.

Rulings

The court granted Williams 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 the events and each defendant’s involvement, state the injuries, and identify the requested relief. The court warned that failure to comply, without good cause, would result in dismissal for failure to state a claim.

The court denied Williams’s motion for appointed counsel without prejudice to renewal at a later date because it was too early to assess the case’s merits. The court deferred deciding whether to exercise supplemental jurisdiction over any state-law claims. It also denied permission to appeal without prepaying fees, stating that an appeal would not be taken in good faith. The order did not decide the merits of Williams’s religious-freedom claims.