Case 2:20-cv-02402-SPL-JFM Document 3 Filed 12/10/20 Page 1 of 59 Jordan A. Kroop (AZ Bar No. 018825) Thomas Ryerson (AZ Bar No. 028073) Janet M. Howe (AZ Bar No. 034615) PERKINS COIE LLP 2901 North Central Avenue, Suite 2000 Phoenix AZ 85012 (602) 351-8000
[email protected] [email protected] [email protected] [email protected] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Stacy Satzman; Daniel Brinauer; Bonnie Huffman; and all those similarly situated; Case No. Plaintiffs, PLAINTIFFS STACY SATZMAN, vs. DANIEL BRINAUER, AND BONNIE HUFFMAN'S MOTION FOR David Shinn, Director of the Arizona PRELIMINARY INJUNCTION Department of Corrections Rehabilitation & Reentry, in his official capacity; *Oral Argument Requested Arizona Department of Corrections Rehabilitation & Reentry; Defendants. 149964045.3 Case 2:20-cv-02402-SPL-JFM Document 3 Filed 12/10/20 Page 2 of 59 I. Introduction Plaintiffs Stacy Satzman, Daniel Brinauer, and Bonnie Huffman are Jewish inmates incarcerated in various state prisons within the Arizona Department of Corrections, Rehabilitation & Reentry (ADC). Plaintiffs hold sincere religious beliefs that require them to consume a kosher diet consistent with Jewish dietary law or kashruth. Previously, ADC provided Plaintiffs well-balanced kosher meals consistent with their religious beliefs and their constitutional rights to practice their religion. On August 1, 2020, however, ADC replaced all specialized religious diets, including Plaintiffs’ religiously-mandated kosher meals, with a “common fare” vegan meal plan. The common fare meal plan is not kosher— it lacks both kosher food products and proper kosher meal preparation. Thus, with every common fare meal that ADC serves, and Plaintiffs consume, ADC violates Plaintiffs’ constitutional rights.