Abuharba v. Claycomb

CourtDistrict Court, S.D. Illinois
DecidedApril 5, 2022
Docket3:21-cv-01077
StatusUnknown

This text of Abuharba v. Claycomb (Abuharba v. Claycomb) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abuharba v. Claycomb, (S.D. Ill. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

MOHAMMED ABUHARBA, #Y16719, ) ) Plaintiff, ) vs. ) Case No. 3:21-cv-01077-SMY ) CHAPLAIN CLAYCOMB, ) CHIEF KEIM, ) LANCE PHELPS, ) FRANK E. LAWRENCE, ) ANTHONY WILLS, ) AMY BURLE, ) SHERRY BENTON, ) ROB JEFFREYS, and ) JOHN DOE, Mail Room Officer, ) ) Defendants. )

MEMORANDUM AND ORDER

YANDLE, District Judge: Plaintiff Mohammed Abuharba, an inmate of the Illinois Department of Corrections (“IDOC”) currently incarcerated at Menard Correctional Center, filed the instant lawsuit pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights. This case is now before the Court for preliminary review of the Complaint under 28 U.S.C. § 1915A. Any portion of the Complaint that is legally frivolous, malicious, fails to state a claim for relief, or requests money damages from an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). The Complaint Abuharba makes the following allegations in the Complaint (Doc. 1): Abuharba purchased religious items for Ramadan 2019 through Islamicbookstore.com on March 29, 2019. When the items arrived at Menard on April 18, 2019, John Doe Mailroom Officer denied Abuharba the items and returned them to the sender. Abuharba grieved the issue to the grievance officer, Warden Frank Lawrence, ARB Member Amy Burle, and IDOC Director Rob Jeffreys. He stated the items were mandatory for his religion and posed no security risk. They denied his grievance and thereby denied him the right to meaningfully practice his religion. During Ramadan 2019, Lawrence refused to allow Muslim inmates, including Abuharba,

to congregate for worship or to break their fast even though there were many safe, secure, and available options to do so. Abuharba grieved the issue to the grievance officer, Warden. Lawrence, ARB Member Sherry Benton, and IDOC Director Jeffreys. He asserted that these practices were a meaningful and mandatory part of his religion and complete denial of congregation was not the least restrictive means of maintaining security. These individuals his grievance and thereby denied him the right to practice his religion. Also during Ramadan 2019, Menard did not feed Muslim inmates proper Halal food to break their fast. Abuharba addressed the issue in a grievance and requested that inmates be allowed to purchase commercially packaged religious food through a vendor. Claycomb and Kein denied the grievance and his request. In their response, they “alluded to donations,” as if Abuharba should

attempt to procure donations, placing a substantial burden on Abuharba. Abuharba grieved the issue to Grievance Officer Lance Phelps, Warden Anthony Wills, ARB Member Benton, and IDOC Director Jeffreys. They denied the grievance and thereby denied him the opportunity to meaningfully practice his religion. Based on the allegations in the Complaint, the Court designates the following claims in this pro se action:1 Count 1: First Amendment claim against John Doe Mailroom Officer, Frank Lawrence, Amy Burle, and Rob Jeffreys for substantially burdening

1Any claim that is mentioned in the Complaint but not addressed in this Order is dismissed without prejudice as inadequately pled under the Twombly pleading standard. See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (an action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim that is plausible on its face.”). Abuharba’s practice of religion by denying him religious items he purchased for Ramadan 2019.

Count 2: Religious Land Use and Institutionalized Persons Act (RLUIPA) claim against John Doe Mailroom Officer, Frank Lawrence, Amy Burle, and Rob Jeffreys for substantially burdening Abuharba’s practice of religion by denying him religious items he purchased for Ramadan 2019.

Count 3: First Amendment claim against Frank Lawrence, Sherry Benton, and Rob Jeffreys for substantially burdening Abuharba’s practice of religion by denying him and other Muslim inmates to congregate for worship and to break their fast for Ramadan 2019.

Count 4: Religious Land Use and Institutionalized Persons Act (RLUIPA) claim against Frank Lawrence, Sherry Benton, and Rob Jeffreys for substantially burdening Abuharba’s practice of religion by denying him and other Muslim inmates to congregate for worship and to break their fast for Ramadan 2019.

Count 5: First Amendment claim against Chaplain Claycomb, Chief Keim, Lance Phelps, Anthony Wills, Sherry Benton, and Rob Jeffreys for substantially burdening Abuharba’s practice of religion by denying him proper Halal food to break his fast for Ramadan 2019.

Count 6: Religious Land Use and Institutionalized Persons Act (RLUIPA) claim against Chaplain Claycomb, Chief Keim, Lance Phelps, Anthony Wills, Sherry Benton, and Rob Jeffreys for substantially burdening Abuharba’s practice of religion by denying him proper Halal food to break his fast for Ramadan 2019.

Discussion Counts 1, 3, and 5 “A prisoner is entitled to practice his religion insofar as doing so does not unduly burden the administration of the prison.” Hunafa v. Murphy, 907 F.2d 46, 47 (7th Cir. 1990). To state a claim under the free exercise clause of the First Amendment, a plaintiff set forth facts sufficient to allege that his “right to practice [his chosen religion] was burdened in a significant way.” Kaufman v. McCaughtry, 419 F.3d 678, 683 (7th Cir. 2005). Here, the allegations in the Complaint are sufficient for Abuharba to proceed on Count 1 against John Doe Mailroom Officer and in Count 5 against Claycomb and Keim. He may also proceed on Count 3 against Warden Lawrence based on an attachment to the Complaint that indicates he was responsible for the decision regarding congregate services for Ramadan. “The alleged mishandling of [a prisoner’s] grievances by person who otherwise did not

cause or participate in the underlying conduct states no claim.” Owens v. Hinsley, 635 F.3d 950, 953 (7th Cir. 2011). Therefore, to the extent Abuharba seeks to bring claims against Lance Phelps, Frank Lawrence, Anthony Wills, Amy Burle, Sherry Benton, and Rob Jeffreys based on their denial of his grievances, he fails to state a claim against them. That said, “a prison official's knowledge of prison conditions learned from an inmate's communications can, under some circumstances, constitute sufficient knowledge of the conditions to require the officer to exercise his or her authority and to take the needed action to investigate and, if necessary, to rectify the offending condition.” Vance v. Peters, 97 F.3d 987, 993 (7th Cir. 1996). Abuharba alleges ongoing constitutional violations that administrative officials would have

the authority to address. As such, he states a plausible claim in Count 1 against Lawrence, Burle, and Jeffreys, in Count 3 against Lawrence, Benton, and Jeffreys, and in Count 5 against Wills, Benton, and Jeffreys. He fails to state a claim against Phelps, who would not have the authority as a grievance officer to rectify the issues Abuharba raised.

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Owens v. Hinsley
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Abuharba v. Claycomb, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abuharba-v-claycomb-ilsd-2022.