Jones v. Carter

Defendant-prison violated plaintiff-prisoner’s rights under Religious Land Use and Institutionalized Persons Act (RLUIPA), where defendant’s refusal to provide plaintiff-prisoner with meat in plaintiff’s meals substantially burdened plaintiff’s exercise of his religion. Record showed that plaintiff observed Islamic hahal dietary restrictions that generally followed Jewish kosher requirements, and that, as cost saving measure, defendant stopped offering defendant and other prisoners kosher meal trays and put defendant and others on vegan diet that would comply with kosher requirements, except that plaintiff’s sect of Islam required its follower to consume meat. Record also showed defendant was providing kosher trays with meat at other prison facilities, and that giving plaintiff kosher trays with meat would not impose any incremental costs to defendant. As such, Dist. Ct. could properly find that for purposes of RLUIPA, providing plaintiff with meatless diet would violate his sincerely held religious beliefs and create substantial burden on his religious exercise, especially where plaintiff could not earn enough in weekly prison wages to purchase meat for the week through prison commissary.  (Dissent filed.)