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Prisoner Education Guide

Muslim Virginia Prisoner Entitled to 2,200 Calories During Ramadan

A federal district court has issued a preliminary injunction requiring the Virginia Department of Corrections (VDOC) to provide a Muslim prisoner with “food items containing 2,200 calories” daily during Ramadan, a month-long period of religious fasting.

This action was brought by Keen Mountain Correctional Center prisoner William R. Couch, who is a Sunni Muslim. Couch’s complaint alleged claims under the First Amendment and Religious Land Use and Institutionalized Persons Act (RLUIPA), stating that prison officials had “deprived him of adequate nutrition and calories during Ramadan” in 2002, 2003, 2004 and 2005.

VDOC operating procedures allow each prison to decide whether to provide Ramadan participants with the same full, hot breakfast that is served to the general prison population or to provide a significantly smaller, cold bag meal. Prison officials always opted to serve the bag meal. During previous Ramadans, Couch was provided with only “approximately 1,000 calories per day.” As a result, he said he experienced weight loss of about 13 pounds, constant hunger, “hunger headaches” and listlessness.

For the Ramadan fast in 2006, prison officials advised Couch they would follow the previous Ramadan procedures. Couch then filed suit on the previous violations of his religious rights and for preliminary injunctive relief to prevent future violations and harm. The court granted the defendants’ motion for summary judgment in part, finding that some of Couch’s claims were barred by the statute of limitations and others for failure to exhaust administrative remedies. The remaining exhausted claims were allowed to proceed. See: Couch v. Jabe, 479 F.Supp.2d 569 (W.D.Va. 2006).

In ruling on the preliminary injunction motion, the district court found the defendants did not present evidence to contradict Couch’s claim that he suffered physical injury of weight loss due to reduced caloric intake during Ramadan. Nor did they refute that the smaller bag breakfast only provides about 1,000 calories per day.

The court held that such weight loss is “an injury that amounts to irreparable harm.” The defendants offered no evidence that the preliminary injunction, if granted, would “disrupt the orderly operation of the food service process at Keen Mountain and other prisons.” As such, the district court entered preliminary injunctive relief requiring prison officials to provide Couch with 2,200 calories daily during Ramadan. See: Couch v. Jabe, USDC W.D.Va., Case No. 7:05-cv-00642-PMS (Sept. 22, 2006).

The case settled on undisclosed terms on March 19, 2007, and the court retained jurisdiction to enforce the settlement agreement between the parties.

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