In Perry v. Curtis, (6th Cir., Aug. 5, 2026), the U.S. 6th Circuit Court of Appeals affirmed the dismissal of a RLUIPA claim by a Michigan inmate who was denied arrangements for a religious fast for the last 10 days of Ramadan. The court said in part:
From 2016 until the end of March 2022, Perry's religious designation was listed as "Nation of Islam," which is one of three religious groups that MDOC has approved to participate in a Ramadan fast. On March 29, 2022, Perry changed his religious designation to "Melanic Islamic Faith," which is not on the list of approved religious groups and instead is considered by MDOC to be a "Security Threat Group."...
... Perry argues that he followed the prison's policy to enable him to fast for Ramadan. That policy required a prisoner "who wants to observe a religious fast or feast [and who] has not already been approved" for one to "submit a written request to do so to the Warden or designee that shall include information"—i.e., "supporting documents"—"regarding the religion's beliefs and practices."...
The defendants met their burden of showing that Perry did not properly request a religious fast in accordance with the policy. Specifically, they presented evidence showing that, although Perry sent three separate kites concerning his desire to fast during Ramadan in 2022, none of those kites qualified as a proper request under the policy. The first kite was not a proper request for an unapproved fast because, at that time, Perry's religious designation was "Nation of Islam," a designation the MDOC had approved for participation in a Ramadan fast; thus, no additional approval was needed.... The second and third kites were not proper requests because Perry merely declared that he was "required to fast the last ten days during the Arabic month of Ramadan," and did not formally request approval to fast.,,,, Nor did the kites provide the required "supporting documents" about Perry's newly proclaimed "Melanic Islamic Declaration of Faith.....
