Imagine being forced to go without food for 15-16 hours when your religious practice only requires 12-13 hours of fasting. This was the reality for Marvin Owens, a Muslim inmate at Jackson County Jail in Michigan during Ramadan 2024. His case raises important questions about religious liberty for incarcerated individuals and the remedies available when religious freedoms are violated.
Marvin Owens, a 34-year-old practicing Muslim incarcerated at Jackson County Jail in Michigan, made multiple requests for dietary accommodations before Ramadan 2024. According to Islamic law, Ramadan observance requires Muslims to fast from dawn until sunset, eating only a pre-dawn meal (suhoor) and a sunset meal (iftar). Despite Owens’ requests, jail officials allegedly failed to provide adequate and timely meals during the holy month. According to a federal lawsuit filed on March 3, 2024, by the Council on American-Islamic Relations (CAIR) Michigan Chapter, Owens wasn’t provided pre-dawn or sunset meals for the first three days of Ramdan. Even when meals were eventually provided, they were reportedly delivered up to two hours late, extending Owens’ fasting period from the normal 12-13 hours to 15-16 hours. It is important to note that Islamic teachings “prohibit a Muslim from extending their fast beyond the moment of sunset, and require that an adherent Muslim hasten to break their fast during Ramadan,” according to the lawsuit.
The quality and quantity of food were also at issue. The lawsuit alleged that Owens received only 1,300 to 1,900 calories per day, which is well below the 2,500 calories recommended for an adult man. Owens was reportedly served inedible food that had been left out, unwrapped and unprotected. On one occasion, the food was so inedible that a deputy advised Owens not to eat it, but also did not provide a replacement.
This case centers on two legal frameworks that protect religious liberty, the First Amendment Right to Free Exercise and the Religious Land Use and Institutionalized Persons Act (RLUIPA). RLUIPA is a federal statute that provides heightened protections for religious exercise in institutions including prisons, prohibiting the government from imposing substantial burdens on religious practice unless the burden serves a compelling governmental interest and uses the least restrictive means of furthering that interest. This case recalls O’Lone v. Estate of Shabazz (1987), where the Supreme Court ruled against Muslim inmates who sought accommodations for Friday prayer services. However, RLUIPA was later enacted specifically to provide greater protection than the constitutional standard established in cases like O’Lone.
This case presents the ongoing tension between religious liberty and governmental interests. Similar to Wisconsin v. Yoder (1972), where the Court recognized that seemingly neutral regulations can impose significant burdens on religious practice, Owens’ case asks whether administrative convenience can justify substantial burdens on religious exercise. This central question parallels the issue in Church of Lukumi Babalu Aye v. Hialeah (1993) where the Court considered whether otherwise neutral policies that disproportionately affect religious practices deserve heightened scrutiny. It is important here to determine whether Jackson County’s failure to provide timely and adequate meals constitutes a substantial burden on Owens based on his religious beliefs and practices. The jail claimed to have a policy for accommodating Muslim inmates during Ramdan, but the implementation appears to have been inconsistent. So, if the jail did have a policy in place, but failed to enact this policy for whatever reason, the question becomes: does administrative difficulty or resource constraints qualify as a compelling governmental interest? I would say no.
I would argue that this case should be ruled in favor of Owens. The evidence clearly shows that Jackson County Jail officials placed a substantial burden on Owens’ religious exercise. By failing to provide pre-dawn or sunset meals for the first three days of Ramadan, and then providing inadequate meals thereafter, prison officials effectively burdened Owens’ ability to practice his faith. Also, there was no compelling government interest to serve delayed and inadequate meals. This is proven by the fact that there actually was a policy in place to accommodate fasting Muslims, which the jail just failed to fulfill. Therefore, Owens should be entitled to the monetary damages outlined by RLUIPA. This would not only provide justice for Owens but also deter future violations of religious liberty in incarceration settings. By ruling in favor of Owens, the Court would affirm that RLUIPA means what it says: incarcerated people have a right to meaningful religious accommodation, and violations of that right must have meaningful remedies.
9 comments:
I agree that the court should side with Owens. There is no compelling interest to not give him adequate and timely meals. Also, there is a substantial burden both religiously and physically. His religion is burden because of the timing, but he is physically burdened by not receiving proper nutrients.
I also agree that the court should rule with Owens. The RLUPIPA should be able to grant reasonable accommodations for people like Owens, even while in jail. Asking to have meals at specific times to practice his faith is a sincere expression of his religion and is a reasonable accommodation. It is important to ensure that individuals, even while incarcerated, can practice their faith, which RLUPIPA is intended to protect.
I agree that the court should side with Owens, as this is a clear violation of First Amendment rights (as well as basic human rights). The facts that there was a policy in place to accommodate fasting Muslims that the jail failed to fulfill proves that there was no compelling government interest to serve delayed and inadequate meals. On the jails side, this case seems more of a disreadard for human life (as seen in the malnutrition aspect) than his religious expression, but his religious expression was ultimaltey affected and thus makes him entitled to the monetary damages outlined by RLUIPA
I agree that the jail placed a serious burden on Owens’ religious practice. Fasting during Ramadan isn’t just about not eating, it has strict timing that is extremely important to Muslims. The jail had a policy in place, yet failed to follow it, which shows this was a significant mistake. Under RLUIPA, Owens deserves a real remedy, and damages are fair with the harm having already been done.
I agree with the blog post and all of the comments. I find that refusing accommodations for a religious holiday to be a violation of Free Exercise rights. I could see if the accommodation was a more frequent thing, that the prison may not be able to accommodate the request, however, the fact that the accommodation is for only a month, I find that less bothersome for the prison. As well, like Dylan mentioned, the timing of meals is very specific and important meaning Owen's is unable to hold her religious practice.
I agree with Owen that institutions must accommodate religious practices unless a compelling reason prevents it and “logistical issues” don’t cut it. Failing to provide timely Ramadan meals isn’t just inconvenient it’s a serious infringement on Owens’ ability to practice his faith which is unconstitutional. The court should recognize this as a clear violation and award damages. Religious freedom should be protected equally, even and especially for the most marginalized.
I normally side with the compelling state interest in cases that bring up issues in jail, but there is no danger in bringing Owens his food in a timely fashion. Even as a prisoner, Owens should be allowed to participate in Ramadan and opt out of the normal meal times. At the same time, the officers should be required to give him a proper meal, once his fast as done. It is important to recongize that it is against his religious obligations to extend his fast and the prison is placing this burden on him. There is absolutely no compelling state interest for the prison to not accommodate him if anything, it is just pure lack of care and laziness.
I agree that the ruling should favor Owens. Like Emma said in her comment, there is no compelling state interest in the mistreatment Owens has experienced, making it flat out inhumane. In prohibiting inmates from practicing their religion, there is a huge violation of the First Amendment. Just because Owens is behind bars does not mean he should be unable to practice his faith. As it has been said, this places a direct burden on Owens' religious freedoms.
I agree that Jackson County Jail clearly failed Owens by not following its own Ramadan meal policy. Making him fast longer and eating spoiled, low-calorie food places a significant burden on both his faith and health. Under RLUIPA, meaningful accommodation—timely pre-dawn and sunset meals—is required. Owens should receive damages to hold officials accountable and ensure prisons honor religious rights for all inmates.
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