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Conway v. Purves, No. 13-CV-10271 (E.D. Mich. 2016)

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Page 1: Conway v. Purves, No. 13-CV-10271 (E.D. Mich. 2016)
Page 2: Conway v. Purves, No. 13-CV-10271 (E.D. Mich. 2016)
Page 3: Conway v. Purves, No. 13-CV-10271 (E.D. Mich. 2016)

FACTS:

Petitioner: Prisoners Respondent: Michigan Department of Corrections (MDOC)

MDOC had a policy that provided for special meals for Muslim prisoners during the month of Ramadan.

These meals contained an average of 1,803 and 1,756 calories in 2011 and 2012, respectively, and were

designed to provide sufficient nutrition. The prisoners, however, claimed to have suffered hunger pains,

headaches, extreme weight loss, dizziness, fatigue, and/or shakiness during Ramadan. Additionally, some

meals were not ḥalāl or were served after sunrise.*

When asked about these inadequacies, an MDOC officer purportedly replied saying that she was not obliged

to follow the Ramadan menu and that the warden was not checking policy compliance. Plaintiffs testified

that they lost 11-20 lbs during Ramadan 2011 and/or 2012 in spite of the meals the prison provided. MDOC

claimed they were entitled to qualified immunity.

*During Ramadan, the ninth month of the Islamic lunar calendar (known as the Hijri calendar), Muslims fast from sunrise to sunset.

Page 4: Conway v. Purves, No. 13-CV-10271 (E.D. Mich. 2016)

Overview:Prisoners’ Reasoning:

1)

2)

MDOC’s Reasoning:

1)

2)

3)

4)

Page 5: Conway v. Purves, No. 13-CV-10271 (E.D. Mich. 2016)

upheld

“failed to establish viable equal protection claim

Fourteenth Amendment claims dismissed,

RLUIPA claims

denied the MDOC qualified immunity

First and Eighth Amendment

Page 6: Conway v. Purves, No. 13-CV-10271 (E.D. Mich. 2016)

evidence

as little as one third recommended

daily calories Ramadan

reasonable official would have known

insufficient to sustain good health violated

First and Eighth Amendment rights