In Obataiye-Allah v. Steward, (9th Cir., May 25, 2021), the U.S. 9th Circuit Court of Appeals vacated an Oregon federal district court’s holding that prison officials were shielded from damages by qualified immunity in a Nation of Islam inmate’s suit complaining that he was denied participation in Ramadan in 2018. The court said in part:
Plaintiff’s declaration established that he has a sincerely held Nation of Islam religious belief and he informed defendants that weekly prayer meetings were not required for Nation of Islam Muslims. The right to free exercise was clearly established in 2018, such that a reasonable official would have known that requiring attendance at weekly prayer meetings as a condition to participate in Ramadan, without consideration of other alternatives to establish sincerity of belief, would violate the First Amendment.
The court also vacated the district court’s rejection of plaintiff’s equal protection “class of one” claim.