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Sabir v. Williams

Case Overview

Muslim Advocates, along with the Law Office of Renee Redman, represents two incarcerated persons—Rafiq Sabir and James J. Conyers—who are challenging a policy banning daily prayer in groups of three or more at Federal Correctional Institution Danbury (FCI Danbury), a low-security federal prison in Connecticut.

The plaintiffs seek to perform the daily Islamic prayer salah together with other Muslims, but have been confronted and threatened with discipline under the prison’s policy banning group prayer. The plaintiffs have challenged the policy as unjustified by security or other concerns, and thus in violation of the First Amendment and the Religious Freedom Restoration Act.

District Court

After the Plaintiffs filed a Second Amended Complaint, the Defendants moved to dismiss, and supplemented their motion on two occasions, when Mr. Conyers was transferred to a lower security institution and when Mr. Sabir was transferred to another federal facility.

On August 27, 2019, the district court granted in part and denied in part the Defendants’ Motion to Dismiss. In this decision, the Court rejected the Defendants’ qualified immunity arguments by plainly stating, “[t]he Court disagrees, at least for now.” Moreover, as to the Plaintiffs’ claims for individual-capacity damages under the Religious Freedom Restoration Act (RFRA), the Court concluded “It [wa]s plausible- at this stage- that qualified immunity would not shield Defendants from liability in their individual capacities.”

Second Circuit

On June 17, 2022, the Second Circuit denied the Defendants’ appeal and affirmed the lower court’s August 27, 2019 decision denying the Defendants’ claim to Qualified Immunity.

Specifically, the Second Circuit held that at this stage of the proceedings, the Defendants are not entitled to Qualified Immunity because the pleadings do not establish that their enforcement of the policy at issue was in service of a compelling interest. Moreover, the Court held that the Plaintiffs’ right to congregant prayer was clearly established at the time of the violation.

After the Second Circuit decision, the Defendants filed a Petition for Rehearing En Banc and Panel Rehearing which is currently pending.


Date filed: June 1, 2018

Court(s):  United States District Court for the District of Connecticut

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