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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.
Overview:Prisoners’ Reasoning:
1)
2)
MDOC’s Reasoning:
1)
2)
3)
4)
upheld
“failed to establish viable equal protection claim
Fourteenth Amendment claims dismissed,
RLUIPA claims
denied the MDOC qualified immunity
First and Eighth Amendment
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
Harvard Law School SHARIAsource
advisors scholars editors