Massachusetts DOC Ordered to Provide Vegan Meals to Buddhist Prisoner
On June 11, 2008, following a non-jury trial in an action brought under the Religious Land Use and Institutionalized Persons Act (RLUIPA), a U.S. District Court directed the Commissioner of the Massachusetts Department of Corrections (DOC) to provide a Buddhist prisoner with a vegan diet.
Daniel Yeboah-Sefah, a devout practitioner of the Quan-Yin Pure Land method of Buddhism, sued the DOC under RLUIPA alleging that his sincerely held religious beliefs were substantially burdened by the DOC’s refusal to accommodate his dietary needs.
Under the Quan-Yin Pure Land method of Buddhism, practitioners are prohibited from “taking the life of Sentient Beings.” Adhering to this precept requires strict observance of a vegan diet.
Over the course of six years, Yeboah-Sefah made repeated requests to the DOC for vegan meals. Unfortunately his requests were met with ridicule, laughter and verbal abuse by prison officials.
Eventually the DOC offered Yeboah-Sefah a “Lacto-diet,” but that was unacceptable because it required him to eat eggs and dairy products, and was prepared with utensils that came into contact with prohibited foods.
Yeboah-Sefah asked prison officials to provide him with a vegan diet by contracting with a vendor that “follows the proper handling, preparation, cooking, and serving of vegan meals.” Yeboah-Sefah pointed to the DOC’s provision of Kosher meals to Jewish prisoners through an outside vendor. Regardless, his request was denied.
Because DOC officials refused to provide Yeboah-Sefah with a vegan diet, he lost significant amounts of weight and was forced to survive off peanut butter purchased from the commissary.
U.S. District Court Judge Mark L. Wolf conducted a bench trial on Yeboah-Sefah’s claims. Following the trial, the court entered judgment in his favor, finding that the DOC had violated his rights under RLUIPA “by denying him a vegan diet.”
Accordingly, the court directed the DOC, beginning on June 20, 2008, to provide Yeboah-Sefah with “vegan meals (which exclude all animal products, including eggs and dairy products), served in the dining hall.” See: Yeboah-Sefah v. Clarke, U.S.D.C. (D. Mass.), Case No. 1:02-cv-10494.
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