Mbonyunkiza v. Beasely, No. 18-3611 (8th Cir. 2020)
Annotate this CaseIowa inmate Napolean-Ahmed Mbonyunkiza was a practicing Muslim whose religious beliefs forbade consumption of pork or pork by-products. In 2017, he filed four separate grievances against the Newton Correctional Facility claiming he had eaten or was served food containing pork. Unsatisfied with the outcome of the grievances, Mbonyunkiza filed a 42 U.S.C. 1983 action in federal district court, alleging violation of his First Amendment rights. The district court granted summary judgment in favor of the correctional facility. The Eighth Circuit, reviewing the grant of summary judgment de novo, concluded Mbonyunkiza failed to show defendants deprived him of a constitutional right and therefore affirmed.
Court Description: [Loken, Author, with Grasz and Stras, Circuit Judges] Prisoner case - Prisoner civil rights. In an action by a Muslim inmate claiming defendants served him food items containing pork or contaminated by contact with pork, the district court did not err in concluding that plaintiff had not satisfied his burden to show that defendants violated his right to free exercise of his religion because four "inadvertent and isolated" incidents failed to show a substantial burden on his ability to practice his religion; absent evidence that an underlying prison regulation or policy violates the Free Exercise Clause, evidence that a corrections official negligently failed to comply with an inmate's sincerely held religious dietary beliefs does not establish a Free Exercise Clause claim under Section 1983.
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