Muhammad v. Mayfield, No. 18-2396 (8th Cir. 2019)
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Plaintiff, an inmate at the ADC, filed suit under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), as well as the First and Fourteenth Amendments, seeking injunctive relief against ADC officials for allegedly refusing to provide him with a daily serving of "halal" meat in accord with his personal religious beliefs.
The Eighth Circuit reversed the district court's grant of an injunction in favor of plaintiff, holding that he failed to exhaust his administrative remedies as required by the PLRA. In this case, plaintiff was required to exhaust ADC's proper grievance procedures regardless of the forms of relief potentially available under the Religious Diet Policy. Furthermore, the court rejected plaintiff's contention that the Religious Diet Policy was, in and of itself, a proper and complete grievance procedure.
Court Description: Grasz, Author, with Shepherd and Melloy, Circuit Judges] Prisoner case - Religious Land Use and Institutionalized Persons Act. Plaintiff alleged defendant prison officials violated the Act by allegedly refusing to provide him with a daily serving of halal meat in accord with his personal religious beliefs, and the court entered an order requiring defendants to provide plaintiff with one serving of fish three or four days a week and one serving of halal or kosher beef, chicken, or turkey three or four days per week. Defendants appeal. Held: Plaintiff failed to exhaust his administrative remedies as required by the PLRA and the district court's judgment is reversed with directions to dismiss the case without prejudice.
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