Rahman v. Fischer (N.D.N.Y. 2012): Shīʿī and Sunnī Accommodations in Prison

Plaintiff Sha-Heed Rahman, a Shīʿī Muslim prisoner in the New York Department of Corrections (“DOCS”), brought this lawsuit against the respondents, various DOCS prison officials, alleging that the respondents violated a settlement agreement, retaliated against him, and conspired to punish him for pursuing his First Amendment rights to exercise his religion and access the courts. The plaintiff originally brought a civil rights lawsuit in 2004, claiming that the respondents violated his First Amendment rights by only employing Sunnī chaplains at DOCS facilities and not allowing inmates to observe Shīʿī holy days. The plaintiff and the respondents entered into a settlement agreement which included the plaintiff’s right to an alternative Shīʿī Friday prayer (jumuʿa) service. In this current suit, the plaintiff claimed that the respondents had failed to provide a separate Shīʿī service and failed to provide Shīʿī study classes. The plaintiff also claimed that when he filed grievances in an attempt to enforce the settlement agreement terms, he was sent to the Special Housing Unit as punishment. The respondents filed a motion to dismiss the claim. The District Court granted the respondents’ motion to dismiss, determining that the plaintiff failed to state a claim. However, the District Court granted the plaintiff leave to amend the claim regarding his First Amendment and retaliation concerns with respect to the provision of Shīʿī study classes.

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