Muflihi v. Rikers Island Employees

Background

Salman Muflihi, who was proceeding without a lawyer, sued under 42 U.S.C. § 1983. He alleged that, while detained at Rikers Island from February 26, 2021, through October 1, 2022, correctional staff interfered with his Muslim religious practices during Ramadan. He alleged that staff failed to provide proper Ramadan meals, did not allow fasting or religious services, failed to provide a Ramadan callout list, and prevented him from participating in or receiving an Eid al-Fitr meal. He also alleged that unidentified correctional officers threatened him with a ticket after he tried to pursue a grievance. He sought money damages.

Court’s analysis

The court screened the prisoner complaint under the Prison Litigation Reform Act. It construed the allegations as raising claims under the First Amendment’s protection for religious exercise and the Religious Land Use and Institutionalized Persons Act, which provides additional protection for institutionalized people’s religious exercise. The court stated that the allegations might be enough to suggest an interference with sincerely held religious beliefs, but they did not provide sufficient information about when the alleged violations occurred or which officers were responsible.

The court also explained that a § 1983 claim requires facts showing each defendant’s direct and personal involvement. Muflihi did not allege what the Islamic Affairs Coordinator, Muslim Chaplain, or Director of Ministerial, Family and Volunteer Services personally did to violate his rights. To the extent he sought to sue those officials in their official capacities, the court said he would need to identify the City of New York and allege that a City policy, custom, or practice caused the violation. The complaint did not do so. The court deferred deciding whether to exercise supplemental jurisdiction over any state-law claims because Muflihi was being allowed to amend.

Ruling

Judge Laura Taylor Swain granted Muflihi leave to file an amended complaint within 60 days. The amended complaint must identify the defendants, provide available identifying information, state the relevant dates, locations, events, injuries, and requested relief, and explain how each defendant was personally involved. It will replace the original complaint rather than supplement it. No summons would issue at that time. If Muflihi failed to amend within the allowed period without showing good cause, the complaint would be dismissed for failure to state a claim. The court certified that an appeal would not be taken in good faith and denied special fee status for purposes of an appeal.