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Iowa Federal Court: Moorish Temple Prisoners Have Right to Celebrate Ramadan

On August 12, 2014, an Iowa federal court held that Moorish Science Temple prisoners have the same right to celebrate Ramadan as Islamic prisoners approved by the Muslim prison chaplain. The court also approved attorney fees of $3,800 and costs of $285.06 despite the case having been largely prosecuted pro se.

Iowa state prisoners Michael Williams-El and James Blair-Bey were not allowed to participate in Ramadan after Imam Taha Tawil, the Islamic Consultant for the Iowa Department of Corrections (DOC), told prison officials that their belief that Drew Ali, founder of the Moorish Science Temple, was a post-Muhammad prophet was contrary to Islam. Based solely on Tawil's assessment, DOC officials refused to authorize Ramadan accommodations--a nightly sack meal, a hot meal and time to meet together in the prison chapel--for Williams-El and Blair-Bey. They then filed a federal lawsuit challenging the denial of Ramadan accommodations.

The court held that the DOC had violated plaintiffs' rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc, et seq., and the Equal Protection Clause of the Fourteenth Amendment. The sincerity of plaintiffs' religious beliefs, including that they must observe Ramadan, was not in question and no security issues had been raised. An "inquiry into what is or is not central to a particular religion has no place in a RLUIPA analysis," rather it should be based upon the individual's sincerely held personal religious beliefs. The court held that denial of the Ramadan accommodations "meaningfully curtails their ability to express adherence in their personal faith and denies them reasonable opportunities to engage in those activities they sincerely believe are fundamental to their religion."

Therefore, the court ordered the DOC to provide Ramadan accommodations to the plaintiffs. However, the DOC was not required to allow plaintiffs to congregate with approved Islamic prisoners celebrating Ramadan. The court authorized $3,800 in attorney fees and $285.06 in costs to court-appointed attorney Rockne Cole who represented plaintiffs for the later parts of the proceedings.

See: Williams-El v. State of Iowa, U.S.D.C. (D.Iowa), Case No. 4:12-cv-00299-TJS.

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Related legal case

Williams-El v. State of Iowa