Abdul Waheed Mohammed v. Wade Anderson, Casey Munsch, Taylor Muhlbeier, Andy Diro, Corey Brubakken, and Kathleen Houston

Summary

The United States District Court for the District of South Dakota grants Abdul Waheed Mohammed leave to proceed in forma pauperis and conducts screening under 28 U.S.C. § 1915A. The court allows official-capacity claims concerning religious accommodations to proceed under the First, Eighth, and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act, while dismissing the Fourth Amendment excessive-force claim without prejudice. The order also addresses Mohammed’s motion for a temporary restraining order concerning Ramadan meals and religious accommodations.

Holdings

1. Official-capacity claims against the jail employees are functionally claims against Pennington County. Liberally construed, Mohammed's allegations that jail officials used their own tactics to deny religious accommodation requests and punished Muslim inmates were sufficient at the screening stage to support an inference of an unconstitutional policy or custom.
2. Mohammed stated a plausible First Amendment free-exercise claim against the defendants in their official capacities.
3. Mohammed stated a plausible First Amendment retaliation claim against the defendants in their official capacities.
4. Mohammed's Fourth Amendment excessive-force claims were dismissed without prejudice for failure to state a claim.
5. Mohammed stated a plausible Eighth Amendment conditions-of-confinement claim against the defendants in their official capacities.
6. Mohammed stated plausible Fourteenth Amendment equal-protection claims against the defendants in their official capacities.
7. Liberally construed, Mohammed's complaint stated plausible RLUIPA claims against the defendants in their official capacities.
8. The court did not issue an immediate temporary restraining order, but directed the defendants to respond to the TRO motion within fourteen days of service and indicated that it could then consider preliminary injunctive relief.

Questions Presented

1. Whether Mohammed should be granted leave to proceed in forma pauperis and have the initial partial filing fee waived.
2. Whether the complaint stated plausible official-capacity claims under § 1983 based on an alleged Pennington County Jail policy or custom denying Muslim religious accommodations.
3. Whether the complaint stated First Amendment free-exercise and retaliation claims.
4. Whether the complaint stated an Eighth Amendment conditions-of-confinement claim based on allegedly inadequate nutrition and delayed meals.
5. Whether the complaint stated a Fourteenth Amendment equal-protection claim based on allegedly disparate treatment of Muslim inmates.
6. Whether the complaint stated a claim under RLUIPA.
7. Whether Mohammed was entitled to an immediate temporary restraining order concerning Ramadan meals and religious accommodations.

Disposition

other