Facts

Mali Williams is a Muslim inmate housed in the Salinas Valley State Prison. In 2017, Muslim inmates observing the Ramadan fast were given two sack meals they could eat before sunrise, replacing the meals they were required to skip during daytime fasting. The sack meals included a box of cold cereal, powdered milk, a coffee packet, two pieces of fresh fruit, six slices of bread, two pieces of American cheese, one peanut butter packet, an ounce of jelly, a bag of chips or pretzels, two graham cracker packets and two beverage packets. The total caloric intake for the sack meal was 1,674 calories, more than the required calories for two meals. Because each item was shelf stable, it would not spoil between delivery and consumption. Also, during the Ramadan timeframe in 2017, Williams was housed in the C-yard that had the highest level of custody in the California Department of Corrections and Rehabilitation (CDCR). CDCR regulations required that inmates with that level of custody were required to be frequently and directly supervised. C-yard had both a chapel and outdoor religious area. Due to the custody level, prison security required that any group prayer be supervised wither by a chaplain or other staff member and therefore, inmates could not be in the closed chapel area without supervision. Alternatively, the outdoor religious area was available as it was already supervised. Williams filed suit against Supervising Correctional Cook Mustafa, Correctional Food Manager Conway, Assistant Food Manager Castillo, Community Resource Manager Hernandez and Warden Foss.

PLAINTIFF'S CONTENTIONS: Plaintiff contended that the sack meals were missing a "main course" as required by the 2008 CDCR Food Service Handbook. The absence of this main course violated his religious rights under the First Amendment's Free Exercise Clause, Religious Land Use and Institutionalized Persons Act, the Equal Protection Clause, and his Eighth Amendment right to adequate food. Plaintiff further claimed that his rights were violated when he was forced to attend Jumu'ah services in the Outdoor Religious Grounds, violating his religious rights under First Amendment's Free Exercise Clause, Religious Land Use and Institutionalized Persons Act, and the Equal Protection Clause. He objected to the outdoor accommodations, arguing that the outdoor religious grounds were inappropriate for religious services.

DEFENDANTS' CONTENTIONS: Defendants noted that one of the sample menus provided by the 2008 Handbook was similar to the sack lunch provided to Williams. Moreover, as to the other claims, plaintiff failed to show triable issues of fact to support his claim. For example, in order to establish a Free Exercise violation, plaintiff was required to show that defendant burdened the practice of his religion, which he failed to do so here. The food provided was healthy and nutritionally and calorically sufficient and accommodated plaintiff's religious dietary needs while considering budgetary, staff and security limitations. As to his Jumu'ah claim, plaintiff's sporadic access to the chapel did not burden his ability to practice his religion. While half of the services occurred outside, half did occur inside, and the sporadic access was due to the lack of an assigned Muslim/Imam spiritual leader, as such supervision was required for prison security. Defendants contended that plaintiff could have sought permission to lead services in the spiritual sense but not authorized to supervise the indoor services in the custodial sense and therefore, on days when no staff member was available to supervise the indoor services in the custody sense, inmates were required to gather outside where they could be observed by on-duty custodial staff.

Result

Defendants' motion for summary judgment was granted.