Ford v. McGinnis (2d Cir. 2003): Prisoner Accommodations for Religious Holidays

The Court reversed the U.S. District Court for the Southern District of New York’s grant of summary judgment in favor of defendant prison officials, John McGinnis, Patrick McGann, and Gordon Lord. Plaintiff Wayne Ford sued under § 1983, alleging a violation of his First Amendment rights by the denial of his request to attend the Eid al-Fitr feast (the holiday at the end of Ramadan); prison officials had moved the event to fall several days after its official occurrence in order that it coincide with a weekend. Defendants argued that their denial of plaintiff inmate’s request to attend the event did not amount to a constitutional violation because the event, once moved, no longer fell on a date of religious significance. The Court concluded that summary judgment was inappropriate because the matter required closer scrutiny of the Turner/O’Lone Test (which balances prisoners' religious accommodation requests with legitimate penological concerns) than the District Court accorded it before finding in favor of either party.

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