Michael Brown v. Peters, et al.

Summary

The United States District Court for the Central District of Illinois screened Michael Brown’s pro se § 1983 complaint concerning allegedly religiously noncompliant Passover meals at Illinois River Correctional Center. The court dismissed the complaint without prejudice under Federal Rule of Civil Procedure 12(b)(6) and 28 U.S.C. § 1915A for failure to adequately allege defendants’ personal involvement, while granting leave to amend within 30 days.

Holdings

1. The complaint failed to state a claim against the chaplain, dietary managers, and dietary supervisors because it did not specifically allege that they personally participated in, or were deliberately indifferent to, the alleged provision of noncompliant Passover meals.
2. The complaint failed to state a claim against the grievance officer and counselor based solely on their alleged mishandling of Plaintiff's grievances because the complaint did not allege that they caused or participated in the underlying religious-food deprivation.
3. The complaint was dismissed without prejudice for failure to state a claim under Rule 12(b)(6) and § 1915A, and Plaintiff was granted a final opportunity to file an amended complaint within 30 days.

Questions Presented

1. Whether the complaint stated a First Amendment free-exercise or RLUIPA claim based on the alleged provision of Passover meals containing yeast or leaven.
2. Whether the complaint adequately alleged personal involvement by the chaplain, dietary managers, and dietary supervisors in the alleged religious or constitutional deprivation.
3. Whether the alleged mishandling of grievances stated a personal-liability claim under 42 U.S.C. § 1983 against the grievance officer and counselor.
4. Whether the complaint should be dismissed without prejudice under Federal Rule of Civil Procedure 12(b)(6) and 28 U.S.C. § 1915A, with leave to amend.

Disposition

dismissed