University of Michigan Law School
Civil Rights Litigation Clearinghouse
new search
view search results
page permalink
Case Name Dowl v. Williams PC-AK-0002
Docket / Court 3:18-cv-00119-HRH ( D. Alaska )
State/Territory Alaska
Case Type(s) Prison Conditions
Attorney Organization Council on American-Islamic Relations (CAIR)
Case Summary
On May 22, 2018, two prisoners at the Anchorage Correctional Complex, both practicing Muslims, brought this lawsuit against the Alaska Department of Corrections (DOC), alleging that prison officials failed numerous times to accommodate their religious needs during Ramadan. According to the ... read more >
On May 22, 2018, two prisoners at the Anchorage Correctional Complex, both practicing Muslims, brought this lawsuit against the Alaska Department of Corrections (DOC), alleging that prison officials failed numerous times to accommodate their religious needs during Ramadan. According to the plaintiffs, during both the 2017 and 2018 Ramadan seasons they received only two bagged meals per day, which were smaller, less in number, and lower in calorie count than the legally required amount. In some instances these meals allegedly included sandwiches containing pork, which they did not eat because of their religious beliefs. They alleged that this “Ramadan Policy” violated the First Amendment's Free Exercise Clause, the Fourteenth Amendment's Equal Protection Clause, the Eighth Amendment’s ban on cruel and unusual punishment, and the Religious Land Use and Institutionalized Persons Act (RLUIPA). Represented by the Council on American-Islamic Relations (CAIR), they filed this lawsuit in the U.S. District Court for the District of Alaska, seeking declaratory and injunctive relief, as well as attorneys' fees.

Since Ramadan was still ongoing at the time the complaint was filed, the plaintiffs also moved for a temporary restraining order or preliminary injunction that would compel prison officials to provide them with nutritionally adequate and pork-free meals through the end of Ramadan on June 15. The case was initially assigned to District Judge John W. Sedwick, but was re-assigned to District Judge H. Russel Holland on May 23, 2018 after Judge Sedwick recused himself (Judge Sedwick did not give a reason in his recusal order). After a hearing, Judge Holland granted the plaintiffs' motion for a temporary restraining order after deciding that they were likely to succeed on their RLUIPA claims. 2018 WL 2392498. The court reserved the issue of a preliminary injunction for later adjudication after the parties briefed the issue. But on May 31, the defendants stipulated that they would comply with the TRO's provisions through the end of the month of Ramadan and any subsequent Ramadan that occurred during the litigation. The plaintiffs withdrew the motion for preliminary injunction as moot.

The DOC filed its answer to the complaint on June 26, 2018, largely denying the plaintiffs' pertinent factual allegations. In addition, the department also asserted several affirmative defenses: that the DOC official defendants in the suit were protected by qualified immunity, that the plaintiffs’ alleged failure to exhaust administrative remedies made a lawsuit in federal court premature, and that the damages suffered by the plaintiffs were de minimis.

On July 6, the plaintiffs filed an amended complaint to further allege that officials at the prison prohibited Muslims from holding religious services or study groups, while allowing Christian prisoners to do the same. The DOC denied these allegations in its answer filed on July 20, 2018.

After the parties proceeded through discovery, the court ordered the case ready for trial by the end of August 2019. But on September 3, the parties notified the court that they had reached a settlement. They filed the agreement with the court on September 5, 2019 and the court filed approval the next day. The court dismissed the case with prejudice and retained jurisdiction to enforce the settlement.

The settlement provided that prisoners fasting during the month of Ramadan would receive meals consisting of 3,000 calories per day, and that they would be two hot meals between sunset and dawn. The defendants agreed to provide pork-free meals with labels indicating as much. And the settlement provided that Muslim prisoners would be permitted to congregate for daily prayers, weekly religious services, and Islamic study groups. The settlement also included that CAIR would provide a four-hour religious sensitivity training to staff statewide. The defendants agreed to pay $102,500 in damages and attorneys' fees. The settlement did not indicate an enforcement period, but that the court would retain jurisdiction over the injunction.

The case appears closed.

Alexander Walling - 07/30/2018
Chelsea Rinnig - 01/15/2020


compress summary

- click to show/hide ALL -
Issues and Causes of Action
click to show/hide detail
Issues
Constitutional Clause
Cruel and Unusual Punishment
Due Process
Equal Protection
Free Exercise Clause
Content of Injunction
Preliminary relief granted
Training
Defendant-type
Corrections
Discrimination-basis
Religion discrimination
General
Conditions of confinement
Food service / nutrition / hydration
Language/ethnic/minority needs
Religious programs / policies
Totality of conditions
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Declaratory Judgment Act, 28 U.S.C. § 2201
Religious Freedom Rest. Act/Religious Land Use and Inst. Persons Act (RFRA/RLUIPA)
Defendant(s) Alaska Department of Corrections
Plaintiff Description Two practicing Muslim prisoners at the Anchorage Correctional Complex.
Indexed Lawyer Organizations Council on American-Islamic Relations (CAIR)
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Preliminary injunction / Temp. restraining order
Attorneys fees
Damages
Injunction / Injunctive-like Settlement
Source of Relief Litigation
Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Filing Year 2018
Case Ongoing Yes
Additional Resources
click to show/hide detail
  See this case at CourtListener.com (May provide additional documents and, for active cases, real-time alerts)
  Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
Date: May 2006
By: Margo Schlanger (Washington University Faculty)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
Book
Date: Jan. 1, 1998
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
3:18-cv-119 (D. Alaska)
PC-AK-0002-9000.pdf | Detail
Date: 09/06/2019
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint [ECF# 1]
PC-AK-0002-0001.pdf | Detail
Date: 05/22/2018
Source: PACER [Public Access to Court Electronic Records]
Order [ECF# 18] (2018 WL 2392498) (D. Alaska)
PC-AK-0002-0002.pdf | WESTLAW | Detail
Date: 05/25/2018
Source: PACER [Public Access to Court Electronic Records]
Amended Complaint [ECF# 35]
PC-AK-0002-0003.pdf | Detail
Date: 07/06/2018
Source: PACER [Public Access to Court Electronic Records]
Settlement Agreement [ECF# 62-1]
PC-AK-0002-0004.pdf | Detail
Date: 09/05/2019
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Holland, Hezekiah Russel (D. Alaska) show/hide docs
PC-AK-0002-0002 | PC-AK-0002-9000
Plaintiff's Lawyers Abbas, Gadeir Ibrahim (District of Columbia) show/hide docs
PC-AK-0002-0001 | PC-AK-0002-0003 | PC-AK-0002-9000
Homer, Carolyn M. (District of Columbia) show/hide docs
PC-AK-0002-0003 | PC-AK-0002-9000
Masri, Lena Fatina (District of Columbia) show/hide docs
PC-AK-0002-0001 | PC-AK-0002-0003 | PC-AK-0002-0004 | PC-AK-0002-9000
Mohamed, Ahmed M. (District of Columbia) show/hide docs
PC-AK-0002-9000
Defendant's Lawyers Cicotte, Matthias (Alaska) show/hide docs
PC-AK-0002-0004 | PC-AK-0002-9000

- click to show/hide ALL -

new search
view search results
page permalink

- top of page -