Sabir v. Williams, No. 19-3575 (2d Cir. 2022)
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Defendants appealed from an order denying their motion to dismiss in part and rejecting their qualified immunity defense against the Religious Freedom Restoration Act ("RFRA") claims of Plaintiffs. Plaintiffs are practicing Muslims whose religion requires them to perform daily congregational prayers with as many other Muslims as are available. According to the allegations in their complaint, while Plaintiffs were incarcerated at the Federal Correctional Institution in Danbury, Connecticut, Defendants enforced a policy that restricted group prayer to the prison's chapel, despite that facility's frequent unavailability. As a result, Plaintiffs were forced to forgo their religious exercise of group prayer to avoid disciplinary action.
The Second Circuit affirmed the district court’s order. The court concluded that the wardens are not entitled to qualified immunity at this stage of the proceedings because the pleadings do not establish that their enforcement of the policy against Plaintiffs was in service of a compelling interest, and it was clearly established at the time of the violation that substantially burdening an inmate's religious exercise without justification violates RFRA.
This opinion or order relates to an opinion or order originally issued on June 17, 2022.
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