Ryidu-X v. Foxwell, 1:18-cv-02213

Background

Plaintiff Malcom Ryidu‑X, a Maryland prisoner and self‑identified Shi'a Muslim, alleged DOC officials at MCI‑H and ECI denied him access to Shi'a religious practice (notably prayer oil) and prevented commissary purchases of hygiene items; he claimed violations of the First, Eighth, and Fourteenth Amendments, RLUIPA, and RFRA.
Two complaints (CCB‑18‑2213 and CCB‑18‑2641) were consolidated; defendants moved to dismiss or for summary judgment and exhaustion and merits issues were briefed.
The court found Ryidu‑X failed to exhaust administrative remedies for commissary/hygiene and retaliation claims (some ARPs were untimely or not pursued to IGO), and those claims were dismissed without prejudice.
The court concluded the religious claim (use/access to prayer oil and ability to practice Shi'a Islam) was administratively exhausted and allowed to proceed on the merits against remaining individual defendants; sovereign‑immunity barred suit against the Division of Correction.
The court denied summary judgment as to the religious‑practice/RLUIPA claim (questions remain whether denial substantially burdens exercise and whether reasonable accommodations are possible) and granted summary judgment dismissing the commissary/retaliation claims and certain defendants.
Plaintiff was given 21 days to move for appointment of counsel; the court reserved ruling on respondeat superior and qualified immunity pending further submissions.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to exhaust administrative remedies	Ryidu‑X argued some ARPs were filed and IGO reviewed, and that institutional actions prevented exhaustion	Defendants argued many claims (commissary, retaliation) were not pursued through required ARP/IGO steps and some appeals were untimely	Court: Commissary and retaliation claims dismissed without prejudice for failure to exhaust; religious oil claim exhausted and proceeds
Free exercise / RLUIPA (access to prayer oil and separate Shi'a services)	Ryidu‑X contends denial of prayer oil and denial of separate Shi'a services substantially burdens his religious exercise and coerces conversion to Sunni services	Defendants say Ryidu‑X is sole Shi'a at ECI, congregate Shi'a services unavailable per policy; he may attend Sunni services or receive limited accommodations; policy relates to penological concerns	Court: Genuine issues remain whether denial of oil imposes a substantial burden and whether accommodation is feasible; summary judgment denied on RLUIPA claim
First Amendment retaliation/harassment	Ryidu‑X alleges refusal to let him buy hygiene items and other acts were retaliatory for his litigation/grievances	Defendants say plaintiff did not exhaust retaliation claim and evidence insufficient to show causal link or adverse action	Court: Retaliation claim dismissed without prejudice for failure to exhaust; no merits ruling due to non‑exhaustion
Sovereign immunity / capacity of DOC as defendant	Ryidu‑X sued Maryland Division of Correction	N/A (defendants invoked immunity)	Court: DOC dismissed under Eleventh Amendment sovereign immunity

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard; legal conclusions insufficient)
Jones v. Bock, 549 U.S. 199 (exhaustion is an affirmative defense; PLRA framework)
Ross v. Blake, 136 S. Ct. 1850 (administrative remedies need be "available"; three circumstances making remedies unavailable)
Woodford v. Ngo, 548 U.S. 81 (proper exhaustion requires compliance with procedural rules)
Turner v. Safley, 482 U.S. 78 (prison regulations valid if reasonably related to legitimate penological interests)
Cutter v. Wilkinson, 544 U.S. 709 (RLUIPA protects institutionalized persons; deference to prison administrators)
Holt v. Hobbs, 135 S. Ct. 853 (RLUIPA/Free Exercise analysis and definition of religious exercise)
Lovelace v. Lee, 472 F.3d 174 (RLUIPA affords greater protection than the First Amendment)