Kravitz v. Purcell, 87 F.4th 111

Jay S. Kravitz, a Jewish inmate, sought to observe Shavuot on June 3–4, 2014 at Downstate Correctional Facility; he practices communal prayer and shared festive meals as part of the observance.
June 3: officers allegedly prevented inmates from attending the scheduled communal meal/prayer, threw paper bags with food at them, and sent them back to their cells; Kravitz prayed alone in his cell.
June 4: officers escorted Kravitz and other Jewish inmates to a dining area; an officer interrupted Kravitz’s prayer after ~30 seconds, shouted and ordered the group to hurry through a communal meal, and prevented customary blessings.
Kravitz filed a § 1983 free-exercise claim against several corrections officers; the district court granted summary judgment to defendants, finding (1) no personal involvement by some officers for June 3 and (2) only a shortened (not substantially burdened) observance on June 4.
The Second Circuit held that a § 1983 plaintiff need not show a "substantial burden" threshold; a burden on a sincerely held religious practice suffices to state a First Amendment claim, and vacated the district court’s grant of summary judgment on that ground while affirming dismissal as to defendants lacking admissible evidence of personal involvement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 1983 free-exercise claims require a threshold showing of a "substantial burden" on religious beliefs	Kravitz: no substantial-burden threshold — showing a burden on a sincere religious practice is sufficient	Defendants: plaintiff must show a "substantial burden" to prevail	Held: No substantial-burden threshold for § 1983; burden on sincerely held religious practice is enough to survive summary judgment
Whether the June 4 events amounted to an actionable burden on religious exercise	Kravitz: officers interrupted prayers and coerced a hurried meal, preventing customary communal worship	Defendants: Kravitz still prayed briefly and ate a communal kosher meal; at most a shortened or de minimis burden	Held: Evidence that officers obstructed sincere religious observance (interrupting prayer, forcing hurried meal) raises a genuine fact issue; summary judgment on this ground was erroneous
Whether certain defendants (Zupan, Purcell, Baker, St. Victor, McCray, Andreu) were personally involved on June 3	Kravitz: those officers were present and participated	Defendants: those officers testified they were not present or were working elsewhere	Held: Affirmed — district court properly granted summary judgment as to those officers due to lack of admissible evidence of personal involvement; remand may permit further identification/discovery re: other officers

O’Lone v. Estate of Shabazz, 482 U.S. 342 (prisoners retain First Amendment free-exercise protections; apply a reasonableness/Turner analysis in prison context)
Turner v. Safley, 482 U.S. 78 (prison regulations valid if reasonably related to legitimate penological interests)
Sherbert v. Verner, 374 U.S. 398 (articulated strict-scrutiny/substantial-burden framework for free exercise claims)
Employment Div. v. Smith, 494 U.S. 872 (neutral, generally applicable laws are not subject to Sherbert strict scrutiny; courts cannot assess centrality)
City of Boerne v. Flores, 521 U.S. 507 (RFRA invalid as applied to the States)
Kennedy v. Bremerton Sch. Dist., 142 S. Ct. 2407 (a plaintiff may prove a free-exercise violation by showing burden on sincere religious practice under policies not neutral or generally applicable)
Holt v. Hobbs, 574 U.S. 352 (RLUIPA/RFRA principles in prison religious-accommodation context)
Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (laws targeting religion are not neutral or generally applicable)
Thomas v. Rev. Bd. of Ind. Emp. Sec. Div., 450 U.S. 707 (definition of burden and role of sincerity inquiry)
Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (RFRA substantial-burden analysis focuses on governmental pressure and concrete consequences)