Williams v. Correctional Officers, 639 F. App'x 55

Plaintiff Randy Williams, a pro se state prisoner, sued under 42 U.S.C. § 1983 and RLUIPA claiming correctional officers delivered Ramadan sunset meals prematurely, forcing him to either eat before sunset (breaking his fast) or forgo meals.
District court dismissed the § 1983 claim for failure to state a claim and also dismissed the RLUIPA claim; Williams appealed but did not challenge the RLUIPA dismissal.
Williams alleged fasting during Ramadan is central to his Islamic practice and that eating before sunset is a "grave spiritual sin" that voids the fast.
The district court treated the burden as de minimis because only a few meals were delivered early and dismissed the free-exercise claim on that basis.
The Second Circuit reviewed the Rule 12(b)(6) dismissal de novo, accepting plaintiff’s factual allegations as true and drawing reasonable inferences in his favor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams plausibly alleged a Free Exercise Clause violation for premature Ramadan meals	Williams: premature sunset meals substantially burdened his sincerely held Islamic belief by forcing him to break or forgo fasts	Defendants: burden was de minimis because only a few meals arrived early	Held: Court vacated dismissal of § 1983 claim—Williams plausibly alleged a substantial burden under Second Circuit precedent
Whether the substantial-burden threshold applies as a prerequisite to a prisoner free-exercise claim	Williams: argued he met the substantial-burden requirement (did not challenge applicability)	Defendants: implicitly relied on substantial-burden analysis to argue no burden	Held: Court assumed the threshold applies but found Williams met it; did not resolve whether threshold is always required
Whether the district court could deem the religious burden unimportant as a matter of law based on frequency of incidents	Williams: centrality of fasting makes each premature meal significant	Defendants: few incidents meant burden was trivial	Held: Court rejected district court’s reliance on nonbinding authority and cautioned against courts second-guessing religious importance; factual pleading survives dismissal
Disposition of RLUIPA claim	Williams did not appeal RLUIPA dismissal	Defendants: N/A	Held: District court’s dismissal of RLUIPA claim affirmed

Chambers v. Time Warner, 282 F.3d 147 (2d Cir. 2002) (Rule 12(b)(6) dismissal reviewed de novo; pleadings construed liberally)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility standard for pleading)
Ford v. McGinnis, 352 F.3d 582 (2d Cir. 2003) (prisoners’ right to meals that comport with religious requirements protects significant religious observances)
McEachin v. McGuinnis, 357 F.3d 197 (2d Cir. 2004) (denial of food that satisfies religious dictates can substantially burden free exercise)
Holland v. Goord, 758 F.3d 215 (2d Cir. 2014) (discusses substantial-burden threshold in prisoner free-exercise claims)
Salahuddin v. Goord, 467 F.3d 263 (2d Cir. 2006) (substantial burden requires showing disputed conduct pressures adherent to modify behavior and violate beliefs)
Jolly v. Coughlin, 76 F.3d 468 (2d Cir. 1996) (definition of substantial burden as pressure to modify behavior)