Terrence T. Miller-Bey v. Ron Neal, et al.

Summary

In this prisoner civil-rights screening order, the court permits Terrence T. Miller-Bey to proceed on First Amendment and RLUIPA claims concerning halal meals, Muslim holiday celebratory meals, and religious services for the Moorish Science Temple of America community. The court also permits related claims for damages against certain individual defendants and injunctive relief against the warden in his official capacity. The court dismisses the remaining claims, including the claims concerning medical care and equal protection, and dismisses three medical defendants.

Holdings

1. The complaint plausibly alleged that denial of a diet consistent with Miller-Bey's sincere religious beliefs substantially burdened his religious exercise, allowing damages claims against Liebel and Walker in their individual capacities and injunctive relief against Neal in his official capacity to proceed.
2. Miller-Bey plausibly stated an RLUIPA claim for injunctive relief against Neal in his official capacity concerning a diet consistent with his sincere religious beliefs, including halal meat and food prepared by Muslims, to the extent required by RLUIPA.
3. Miller-Bey plausibly alleged that prison officials treated the MSTA Community less favorably than Christian and other Islamic groups in providing celebratory meals, allowing a damages claim against Liebel and official-capacity injunctive relief against Neal to proceed.
4. Miller-Bey plausibly stated First Amendment claims against Buss, Liebel, and Walker for discontinuing MSTA religious services and official-capacity injunctive claims against Neal under the First Amendment and RLUIPA.
5. Miller-Bey failed to plausibly allege an Equal Protection violation because he did not plead facts showing that defendants purposefully singled out the MSTA Community and intentionally discriminated against him because of his Muslim faith.
6. Miller-Bey failed to plausibly allege that Marthakis, Pflughaupt, Turner, Liebel, or Walker were deliberately indifferent to his medical needs.

Questions Presented

1. Whether Miller-Bey plausibly stated First Amendment Free Exercise claims based on denial of a diet consistent with his sincere religious beliefs.
2. Whether Miller-Bey plausibly stated First Amendment Establishment Clause claims based on unequal provision of religious holiday meals and discontinuation of MSTA religious services.
3. Whether Miller-Bey plausibly stated RLUIPA claims for injunctive relief concerning religious meals, holiday observances, and religious services.
4. Whether Miller-Bey plausibly stated a Fourteenth Amendment Equal Protection claim based on alleged disparate treatment of the MSTA Community.
5. Whether Miller-Bey plausibly stated Eighth Amendment deliberate-indifference claims based on allegedly inadequate medical care.

Disposition

other