The Plaintiff, Marcus Leeotis Watts, sued the Respondents, various prison officials at the Perry Correctional Institution in South Carolina, for allegedly violating his rights under RLUIPA and the First Amendment when the prison failed to provide Muslim prisoners with ḥalāl meat. The Respondents contended that the vegetarian meal option that complied with Islamic law was adequate, and sought summary judgment. The District Court granted summary judgment for the Respondents, citing earlier case law providing that the failure to provide a ḥalāl diet containing meat did not substantially burden prisoners' exercise of religion because a Muslim prisoner is not religiously-obligated to eat meat.
Intisar Rabb, Contributed by Intisar Rabb, Senior Scholar
U.S. District Court for the Northern District of Illinois, Contributed by SHARIAsource StaffMore Commentary
The Danial Latifi illustrates the impact of communal tensions on the Supreme Court’s decision-making process, and the careful lines it attempts to draw in order to promote Muslim women’s gender equity while also limiting its intervention into Islamic personal law to avoid potential backlash.
Zubair Abbasi, Contributed by Zubair Abbasi
Muhammad Zubair Abbasi, Contributed by Zubair Abbasi
Holding: A witness must believe in a God in order to be sworn in court. A court may hear testimony about a witness’ belief or disbelief to determine whether the witness may be sworn. Whether a witness believes or disbelieves in a future state of rewards and punishments goes only to his credibility as a witness, not to his ability to testify.
Procedural posture: Plaintiff objected to the competency of a witness in a case before a Massachusetts court of common pleas, and the Court overruled the objection. The jury found for defendants, and plaintiff appealed. Islamic law is not directly relevant, except that the court notes that a “mahometan” belief suffices for swearing an oath.
Judgment: Reversed and objection sustained in an opinion authored by Justice Wilde.
Facts: The plaintiff objected to the competency of a witness on the grounds that the witness did not believe in God. The plaintiff offered testimony from other witnesses to prove this assertion. The lower court declined to hear the testimony and overruled the objection. On appeal, the Supreme Judicial Court of Massachusetts noted that the general rule of evidence does not allow a witness to disqualify himself by declarations not made under oath. However, there is an exception for cases such as this one to prove the witness’ belief or disbelief in God, as only those who believe in God may testify in court. Article 2 of the Massachusetts Constitution—which protects citizens from being “hurt, molested, or restrained, in [their] person, liberty, or estate, for worshipping God in the manner and season most agreeable to the dictates of [their] own conscience”—does not apply to atheists, and even if it did, rejecting a witness for being an atheist would not violate the statute. Therefore, the Court concluded, the plaintiff should have been allowed to introduce testimony showing that the witness did not believe in God and therefore could not be sworn.
U.S. District Court for the Northern District of New York, Contributed by Katherine Gonzalez
U.S. District Court for the Western District of Washington, Contributed by Katherine Gonzalez