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Muslim inmate John McGlothlin brought a case under §1983, alleging that the prison chaplain and other prison officials violated his right to free exercise under the First Amendment. The plaintiff claimed that Muslim inmates were treated differently from fellow inmates of other religious beliefs, exemplified by comparing the announcements on the bulletin board for Muslims with one run by the Christian Fellowship. A report by the U.S. Magistrate recommended that this case should be dismissed, and the District Court agreed. Specifically, the Court found that the plaintiff’s claims against the prison’s non-denominational chaplain should be dismissed as the chaplain was not a state actor; it further dismissed the claims against the other officials because the plaintiff’s claims failed to demonstrate a disparity of treatment based on religion.

Muslim inmate Imam Abd’Allah Halim Abdul Akbar (aka Phillip M. Hudson) sued several prison officials under §1983, alleging a violation of his First Amendment free exercise rights. Specifically, the plaintiff alleged that the prison denied his attempts to start a Muslim inmate group. The prison officials argued that the denial resulted from the plaintiff’s failure to follow the proper procedures for creating such a group. The Court granted summary judgment in favor of the defendant, concluding that the prison did not deprive the plaintiff of his ability to practice his religion and that the regulations governing creation of inmate groups were consistent with legitimate penological objectives of preventing gang activity and maintaining order in the prison population. 

Faris Matiyn, an inmate at the Attica prison, mounted a § 1983 claim against the commissioner of the New York State Department of Corrections and prison superintendent Walter Kelly. The plaintiff alleged that the prison violated his First Amendment free exercise right by not allowing Sunnī and Shīʿī Muslims—the two major Muslim denominations—to have separate worship services. The Court granted summary judgment in favor of the defendant, concluding that the plaintiff did not speak for the majority of the Sunnī Muslim community and that keeping the two groups together satisfied legitimate penological objectives, such as maintaining a safe prison environment. 

Prison inmate Lawrence Cochran filed a §1983 claim against prison officials for allegedly violating his First Amendment rights by not allowing him to have food in his cell at night to break the Ramadan fast and by limiting his attendance of religious services. The Court granted the motion for summary judgment in favor of the defendants, holding that incarceration necessarily curtails some freedom, and that, in this context, the curtailment did not go so far as to place a substantial burden on Muslim inmates’ ability to practice their religion.

William Knuckles and several other inmates, all adherents of the Nation of Islam, filed a §1983 claim against prison officials, alleging a violation of their First and Fourteenth Amendment rights. Specifically, they alleged that they were not allowed to correspond with their religious leaders, receive books and periodicals, "wear Muslim medals," or have a special dietary plan. In finding that the inmates were entitled to be visited by qualified ministers, the Court cautioned that all meetings should remain of a religious nature and could be supervised by prison officials.

In a divorce proceeding, the Circuit Court of Fairfax County upheld a couple’s marriage contract. On appeal, defendant Ali Afghahi raised several arguments against the validity of the contract, and claimed that upholding it would be inequitable; he also made several evidentiary objections, including that the marriage contract as admitted was not the original document and should therefore be barred according to the “best evidence rule.” He further argued that as no expert was called to testify about the meaning of marriage in Islamic cultures, the judgment was unenforceable. The appellate court rejected these arguments and affirmed the judgment against him (and in favor of the validity of the marriage contract), concluding that his objections were untimely because he had not raised them in the lower court.

At issue in this case is the validity of a marriage performed in the Islamic tradition, where the husband sought an annulment of an initial “traditional” marriage and recognition of a subsequent civil marriage. The law of the Philippines does not require a couple to obtain a marriage certificate if their marriage is performed according to the Islamic tradition; accordingly the couple married under traditional Islamic law and obtained no certificate. In seeking annulment of that marriage and recognition of a subsequent marriage, appellant Rafiqul Islam argued that the first marriage was not official; he further argued that the union was not truly Islamic because his so-called wife was not Muslim, because the wedding ceremony was performed by a clerk rather than a religious official, and because neither party intended to enter into a marital relationship. On appeal, the Court upheld the trial court’s decision that the first marriage was a legitimate, state-recognized union, and thus that any subsequent marriage would be considered void.

In divorce proceedings, a wife appealed the decision of the Oakland Circuit Court Family Division, granting her husband’s motion to dismiss her claims and recognize their previous divorce, which occurred when the couple was in India. Specifically, she contested the validity of the “triple ṭalāq” divorce (a version of final, irrevocable divorce under Indian and Islamic law, performed unilaterally by the husband) that her husband performed in India, and filed for divorce in Michigan. The trial court concluded that the certificate of divorce that the defendant husband produced from their earlier divorce was sufficient evidence to dismiss the case under Michigan Compiled Laws 2.116(C)(7) (which bars claims based on prior judgment). The Court of Appeals reversed and found in favor of the plaintiff, concluding that the Indian divorce violated due process requirements of the Fourteenth Amendment and the Michigan Constitution art. 1, § 2, as it gave the wife no chance to plead her case concerning the divorce before a court. The Court also concluded that allowing the divorce to stand would be contrary to state public policy, as it privileged the Muslim personal law of India (which placed women in a weaker position regarding property division in the event of a divorce than would Michigan state law) over Michigan state law and the rights and protections extended to persons living in the state.

The Ohio Court of Appeals affirmed the trial court’s refusal to enforce an Islamic marriage contract, which called for a postponed dowry (mahr) owed by the husband to the wife upon death or divorce of $25,000. The Court found that the groom was coerced into signing the agreement, and thus it was not valid. The Court did not delve into the potential First Amendment Establishment Clause issues considered by the Franklin County Court of Common Pleas.

The Texas Court of Appeals reversed a state district court’s decision to uphold an Islamic marriage contract that awarded the wife a deferred dowry (mahr), an amount agreed upon at the time of marriage and due to the wife from the husband or his estate upon death or divorce, of $50,000. The district court had concluded that the amount was due pursuant to a marital contract made by the parties “in contemplation of a forthcoming marriage,” constituting “a valid, binding, and enforceable contract under Sections 4.001-003 of the Texas Family Code.” The appellate court reversed and remanded to the lower court, concluding that the agreement was not a valid premarital contract under the state law, defined as “an agreement between prospective spouses made in contemplation of marriage,” because the religious wedding ceremony occurred before the contract was signed. As the contract fell outside of the definition of premarital contract, the Court concluded that it could not be enforced like one. 

The plaintiff petitioned the Court to bury his wife according to Islamic legal requirements over the objections of her family. The plaintiff claimed that he and his wife had shared the Islamic faith and had married by way of an Islamic marriage ceremony the previous year. However, they never obtained a marriage license, and there was no proof of her faith or burial wishes. The Court found in favor of the deceased’s parents, concluding that, without a marriage license, the plaintiff was not her surviving spouse before the law. Therefore, the deceased was to be buried according to her parents' wishes. The Court did not view this as a potential First Amendment Free Exercise issue.

The appellate court upheld the Superior Court of Orange County’s refusal to divide marital property in the context of a divorce according to Islamic law. The plaintiff introduced a marriage certificate as a “premarital contract,” which, among other things, lays out a set amount to be paid to the wife in the event of a divorce. The lower court refused to consider the certificate a “contract,” as it was not clear that both parties were expressly agreeing to the same terms, consistent with their understanding of Islamic law and custom.

This Court reversed the decision of the Circuit Court of Hillsborough County that prevented a wife from collecting her deferred dowry (sadaq), the dowry due from the husband to the wife upon marriage, a portion of which is deferred by agreement to be paid upon death or divorce. The husband argued that, under Islamic law, the wife forfeits her contractual right to the deferred dowry if, as here, she is the one to seek the divorce. This Court upheld the contract, holding that it was binding because there was a meeting of the minds, and the parties agreed that the deferred dowry would be due upon divorce.

In a divorce proceeding involving a prenuptial agreement (Islamic marriage contract) between a Muslim husband and wife, the California Court of Appeals considered the validity of a provision requiring the husband to pay 3,000 Jordanian dinars as well as 2,000 dinars of either cash or household furniture as a “deferred dowry” (known as mahr or ṣadāq) due to the wife upon death or divorce. The husband claimed that the deferred dowry is not due where, as here, the wife initiates the divorce proceeding. The court concluded that, regardless of the individual claims, requiring payment of one party to the other upon divorce was an example of prohibited “divorce profiteering” and that, “if the court had accepted the position of wife’s expert, the contract would not have been enforceable under the public policy of the state.” Accordingly, the Court upheld the lower court's decision not to enforce that provision of the agreement.

This case was brought on appeal from the U.S. District Court for the Western District of Virginia, which granted summary judgment in favor of the defendants, prison officials (Warden Jack Lee, Assistant Warden Gene Shinault, and Correctional Officer K. Lester). Petitioner Leroy Lovelace was removed from a “pass list” (which gives inmates access to Ramadan prayer services and special meals) after prison officials claimed that he broke his fast by eating during the day. Lovelace argued that his removal was due to his complaints about expired food, and was thus in violation of his First Amendment right to free exercise of religion, the Fourteenth Amendment right to due process, and the requirements of Section 3 of the Religious Land Use and Institutionalized Persons Act (RLUIPA) (protecting prisoners from having their religious practices substantially burdened, without a compelling government interest). Section 3 of RLIUPA states that “No government shall impose a substantial burden on the religious exercise of a person residing in or confined to an institution, as defined in section 1997 of this title, even if the burden results from a rule of general applicability, unless the government demonstrates that imposition of the burden on that person--is in furtherance of a compelling governmental interest; and is the least restrictive means of furthering that compelling governmental interest.” 42 U.S.C.A. §2000cc-1(a). The Court vacated the grant of summary judgment in favor of Officer Lester, the prison official who reported the alleged fast breaking, as well as against Warden Lee, who was in charge of overseeing the prison, concluding that both officials played direct roles in the incident. The Court remanded the case to the district court to determine whether the plaintiff had made out a valid due process claim, and the Court affirmed the remainder of the district court’s grant of summary judgment in favor of the defendants.

Plaintiffs, Muslim prisoners, sued the Massachusetts Department of Corrections, alleging violations of state and federal law, including the First Amendment of the U.S. Constitution, § 1983, and the Religious Land Use and Institutionalized Persons Act (RLUIPA). Plaintiffs alleged that being patted down by female prison guards violated their First Amendment free exercise rights inasmuch as it contravened the tenets of their Islamic faith, which forbids intimate contact between unrelated members of the opposite gender. The Court granted the defendants’ motion for summary judgment for most of the claims, but denied it with respect to the RLUIPA and the Massachusetts General Law claims, concluding that a jury would best be able to determine whether the alleged infraction violated the terms of these two statutes.

Plaintiff James McRoy claimed that prison officials violated his First Amendment free exercise rights by cancelling some of the scheduled Muslim prayer services without notice, limiting the number of services that Muslim inmates could attend each week, limiting the number of Muslim inmates who could attend each service at any given time, subjecting Muslim inmates to strip searches before they could leave their cells to attend services, prohibiting imams from bringing religious publications onto the prison’s premises, and prohibiting Muslim inmates from exclusively living together in one of the prison’s living units. The prison officials, however, claimed that their actions resulted from a lack of volunteers to organize services and the need to curtail inmate movement on some days because of heightened security concerns. The Court held that McRoy did not sufficiently demonstrate that a jury could conclude that he had been subjected to a violation of his rights. It thus entered summary judgment in favor of the defendants.

The Court reversed the U.S. District Court for the Southern District of New York’s grant of summary judgment in favor of defendant prison officials, John McGinnis, Patrick McGann, and Gordon Lord. Plaintiff Wayne Ford sued under § 1983, alleging a violation of his First Amendment rights by the denial of his request to attend the Eid al-Fitr feast (the holiday at the end of Ramadan); prison officials had moved the event to fall several days after its official occurrence in order that it coincide with a weekend. Defendants argued that their denial of plaintiff inmate’s request to attend the event did not amount to a constitutional violation because the event, once moved, no longer fell on a date of religious significance. The Court concluded that summary judgment was inappropriate because the matter required closer scrutiny of the Turner/O’Lone Test (which balances prisoners' religious accommodation requests with legitimate penological concerns) than the District Court accorded it before finding in favor of either party.

The Court affirmed a decision by the U.S. District Court for the Western District of Wisconsin, granting summary judgment in favor of the plaintiff, Jerry Charles, who alleged a violation of his rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA) to practice his religion. Specifically, the plaintiff requested accommodations that would allow him to have prayer oil, which he contended was a necessary part of his religious practice. The Department of Corrections challenged RLUIPA as unconstitutional, but the Court upheld the constitutionality of the statute.

Plaintiff Kevin Murray, an American taxpayer, sued Treasury Secretary Timothy Geithner and the Board of Directors of the Federal Reserve, arguing that the Emergency Economic Stabilization Act (EESA), which established the Troubled Asset Relief Program (TARP), violated the Establishment Clause of the First Amendment by allowing funds to be used to support companies that invest in sharīʿa-compliant financial instruments. Applying the Lemon Test to assess whether there was excessive entanglement between religion and state related to Islamic financial instruments, the Court concluded that there was not; specifically, it determined that the Islamic financial instruments comprised only a small percentage of the complete business portfolio, that the purpose of the EESA was not religious, and that the primary effect of utilizing the Islamic financial instruments did not support or hinder any religion. Accordingly, the Court granted summary judgment in favor of the defendants.

At issue is this case is an Islamic financial instrument called a mudaraba agreement, by which a bank enters into a profit-sharing arrangement with a borrower. The Agreement at issue includes a clause stating that any disagreements are to be settled through arbitration in the Bahamas. The Court refused to uphold the Agreement because Vinewood Capital was not a signatory to the agreement, and thus denied the motion to compel arbitration of Vinewood’s claims. In May of 2011, the Court dismissed the appeal and closed the case.

Plaintiff Kevin Murray, an American taxpayer, sued Treasury Secretary Geithner and the Board of Governors of the Federal Reserve, challenging use of the Troubled Asset Relief Program (TARP) funds created by the Emergency Economic Stabilization Act (EESA) to bailout AIG, a “market leader in Sharia-compliant financing.” The Court denied summary judgment in favor of the defendant, finding that the bailout of AIG by the government may raise First Amendment Establishment Clause issues. This decision was overturned in a 2011 appeal, in which this same Court granted summary judgment in favor of the defendant, holding that the plaintiff had not made out a sufficient case that would allow a jury to conclude, under the Lemon Test (which assesses whether there is excessive entanglement of the Government with religion) that the Treasury Secretary violated the Establishment Clause by allowing AIG investment in sharīʿa-compliant financial instruments.

The U.S. accused a group of defendants of financial dealings with terrorists, on the basis that they had entered into Islamic financial agreements—specifically a profit-sharing arrangement known as a mudaraba contract—with a known leader of Hamas, a relative of one of the members of the defendant group. The U.S. District Court for the Northern District of Texas found them guilty. On appeal, this Court held that there was enough evidence to suggest that the defendants knew that their relative was a designated terrorist but continued to do business with him. The Court thus upheld the District Court’s guilty verdict.

The Court granted the defendant Marriott International’s motion for summary judgment in part and denied it in part. Plaintiff Nagy Edrisse sued Marriott and several of its employees under Title VII, § 1981, the New York State Human Rights Law, and the New York City Human Rights Law. The plaintiff alleged that the hotel created or tolerated a hostile work environment in that his direct manager made frequent derogatory racial, religious, and ethnic statements, including asking the plaintiff whether he was going to blow up the building and whether he was a terrorist. Furthermore, the plaintiff claimed that the hotel fired him out of discriminatory animus based on his religion, race, and ethnicity. The defendant argued that the plaintiff was fired due to inappropriate behavior at the workplace (including using racial slurs directed at fellow employees), rather than his race, religion, or ethnicity. The Court dismissed the claim against the employees who were not directly involved, but denied summary judgment for the defendants, holding that the facts were sufficient to make out a prima facie case to move forward. In other words, the Court concluded that a jury could consider the evidence presented to be severe and pervasive enough to allow for a finding of a hostile work environment.

The Court denied defendant Merrill Lynch’s motion for summary judgment, adopting the opinion of the magistrate judge, which held that the employee established a prima facie case of discrimination. Plaintiff Abdul-Giyath Mayale-Eke sued his former employer and direct supervisor under Title VII, §1981, the Rhode Island Fair Employment Act, and the Rhode Island Civil Rights Act. The plaintiff alleged that, as a Muslim who had immigrated from Nigeria, he was treated differently and ultimately fired from his position as an investment specialist because of his race, national origin, and religion; specifically, he claimed that he was frequently asked questions about his heritage and was subject to derogatory comments. Defendant Merrill Lynch claimed that it fired plaintiff after giving him numerous warnings of his failure to meet set performance standards. The Court ultimately denied the defendant’s motion for summary judgment, concluding that the plaintiff had alleged enough specific facts to make the claim not just conceivable but plausible before a jury.

Masroor Siddiqui, a Muslim of Pakistani origin, sued his former employer, Autozone, under Title VII, alleging race-based harassment; discrimination based on race, ethnicity, national origin, and religion; and retaliation. The plaintiff claimed that he was subjected to a hostile work environment when, after 9/11, he was barraged with racial epithets. He further alleged that he was passed by for promotions because of his race, religion, and national origin (citing comments from his supervisor that they would never promote “people like him”), and that he was ultimately terminated as a result of these factors. The defendant argued that, even if the court found that the plaintiff had made out a prima facie case of discrimination, the company legitimately denied the promotion of, and ultimately fired, the employee because of poor work performance. The Court entered summary judgment in favor of the defendant on the hostile work environment claim, concluding that no jury would consider the evidence produced by the plaintiff severe or pervasive enough for a hostile work environment claim; however, the Court denied the motion for summary judgment in respect to the promotion claim, allowing the case to go forward.

A group of Muslim employees sued their employer, Celestica Corporation, a manufacturing company, and Adecco USA, Inc., a temporary employment agency, under Title VII and the Minnesota Human Rights Act. The plaintiffs alleged discrimination on the basis of religion, and also claimed that the defendants refused to reasonably accommodate their religiously-mandated prayer schedule despite repeated requests. The defendants argued that they offered the plaintiffs options to accommodate their prayer schedule, including changing shifts. The Court, however, found that there was enough evidence to allow a jury to conclude the defendants did not reasonably accommodate the religion of the plaintiffs; it thus denied the defendants’ motion for summary judgment.

On appeal from the U.S. District Court for the District of Minnesota, the Court upheld the lower court’s grant of summary judgment in favor of the defendant. The EEOC brought a case under Title VII on behalf of Asthma Suliman, a Muslim employee of Kelly Services (a temporary employment agency), alleging religious discrimination. Suliman claimed that the company required her to remove her headscarf (khimār) to work at Nahan (one of Kelly’s work placement facilities) because of the risk that loose clothing posed to the wearer due to the heavy machinery. The defendant company argued that, even if the Court determined that the plaintiff had made out a prima facie case of discrimination, the company had “a legitimate, nondiscriminatory reason for the adverse employment action.” An earlier precedent, Ollis v. Hearthstone Homes, Inc., recognized the operation of heavy machinery as a legitimate basis for requiring headscarf-removal and as a proper defense to a claim of discrimination in such instances. The Court affirmed the lower court’s decision, concluding that the EEOC could not prove that the employee was discriminated against as a direct result of her religious beliefs, and that the defendant had demonstrated a safety-related reason for the lack of accommodation.

Plaintiff Tarick Ali sued his former employer under Title VII and the D.C. Human Rights Act, claiming he was discriminated against on the basis of his religion. As an EMT and firefighter for the District of Columbia, Ali alleged that the District subjected him to disparate treatment and a hostile work environment after he filed a complaint about his supervisor’s lack of accommodation of his prayer schedule. He alleged that, on several occasions, his direct supervisor told him that he must choose between his religion and job, publicly mocked him when he returned from prayer, and ridiculed him for filing an internal complaint regarding the alleged discrimination. The Court denied the defendant government’s motion for summary judgment, concluding that the evidence presented could allow a jury to find that the plaintiff was treated adversely because of his religion and was subjected to a hostile work environment on that basis.

Plaintiff Sultan Chowdhury sued his employer under Title VII for discrimination, retaliation, and creating a hostile work environment. In this action, the Court reviewed the defendant’s supplemental motion for summary judgment based on plaintiff’s hostile work environment claim. (The defendant had previously filed a motion for summary judgment that was dismissed on the discrimination and retaliation claims, and the Court ordered further briefing for the hostile work environment claim.) The plaintiff also amended his previous claim, detailing the hostile work environment claims, alleging discrimination on the basis of his religion (Islam), including belittling and humiliation in front of his co-workers, exclusion from important meetings, and interference with his attempts to seek transfer. The Court held that the named instances provided sufficient evidence for jurors to find that the conduct was severe or pervasive enough to allow a hostile work environment claim. It therefore denied the defendant’s motion for summary judgment, allowing the case to move forward to trial. On March 7, 2011, a jury trial delivered a partial verdict in the case, as the jury did not answer all of the questions raised but awarded compensatory damages in the amount of $1,125,000. The Court directed the parties to file a joint status report in August 2011 if they were seeking mediation on the outstanding issues.

The plaintiff sued her former employer, Neiman Marcus, under Title VII, alleging discrimination based on religion, race, color, and national origin; failure to accommodate her religion; failure to stop harassment; and retaliation for her filing of a religious and national origin discrimination claim with the Equal Employment Opportunity Commission (EEOC), which allowed her suit to proceed in court. The defendant company argued that, because of the statue of limitations, the plaintiff failed to make a claim. Many of the plaintiff’s claims, including allegations of her co-worker directing racial epithets at her, and being compelled to work on religious holidays, were time-barred and thus could not be introduced to the court. The court found that the plaintiff failed to make a prima facie case of discrimination as required by McDonnell Douglas, concluding that she did not prove that she was treated differently because of her religion, race, or national origin. Accordingly, the Court granted summary judgment in favor of the defendant company on these claims; however, the Court denied the company’s motion for summary judgment on the hostile work environment claim, concluding that a jury could consider allegations that the company permitted so-called sale-stealing, when an employee rings up the sale of a client that a co-worker was working with thereby receiving their commission, to be an adverse employment action in the claim that was not time-barred, and thus the suit on this issue could move forward.

A Pakistani Muslim plaintiff sued her former employer, JP Morgan Chase, under Title VII and the Age Discrimination in Employment Act (ADEA), alleging that she was subjected to a hostile work environment, constructive discharge, and disparate treatment. Specifically, the plaintiff alleged that she received a lower salary than her co-workers in the same position and that her reasonable requests to work a different shift so she could care for her daughter were denied. The Court granted the defendant’s motion for summary judgment. The Court concluded that the incidents that the plaintiff cited to support her claim of a hostile work environment were not severe or pervasive enough to allow a jury to find for the plaintiff. Furthermore, the court did not see any adverse employment action as a result of alleged disparate treatment (which is an element that the McDonnell Douglas Corp. v. Green test for discrimination requires in cases lacking direct evidence). Finding that the plaintiff failed to establish a prima facie case of discrimination or retaliation, the Court granted the motion for summary judgment in favor of the defendant.

A Muslim woman, Zahra Mowafy, sued her former employer and her supervisors under Title VII and under the Age Discrimination in Employment Act (ADEA), alleging discrimination and job termination based on religion, race, national origin, and age. The plaintiff alleged that, during her time working for the company, it had created a hostile work environment by failing to stop her student interns from mocking her religious prayer rituals or asking insensitive questions about her religion. The Court found that, although the plaintiff narrowly made a prima facie case demonstrating religious discrimination (as no other non-Muslims were similarly fired), the defendant company had non-discriminatory reasons for firing the plaintiff, specifically poor work performance (which was not disputed by the plaintiff). Furthermore, on the hostile work environment claim, the Court concluded that the incidents detailed by the plaintiff were not severe or pervasive enough to allow a successful claim. Accordingly, the Court granted the motion for summary judgment is favor of the defendant. 

A female Muslim police officer, Kimberlie Webb, sued the City of Philadelphia under Title VII and the Pennsylvania Religious Freedom Protection Act, alleging religion- and gender-based discrimination. Specifically, the plaintiff objected to the City barring her from wearing a headscarf (ḥijāb) with her police uniform, and argued that the prohibition amounted to a failure to accommodate her right to free exercise of religion under the First Amendment. The City argued that the bar was consistent with Philadelphia Police Directive 78 and that allowing her to wear religious garb would cause an undue burden on the City and the Police Department, in that it would compromise a look of cohesiveness and uniformity among officers. The Court concluded that the plaintiff failed to exhaust internal remedies regarding her claim of gender discrimination and found the bar on the headscarf to be a compelling state interest. Accordingly, the Court upheld the U.S. District Court for the Eastern District of Pennsylvania, granting the City’s motion for summary judgment.

Muslim plaintiff Iqbal Sulehria sued his employer, the New York City Department of Correction, and related officials under Title VII, §1983, and New York State and City anti-discrimination laws, alleging religious and national origin discrimination as well as retaliation for filing a claim with the Equal Employment Opportunity Commission (EEOC) and through the prison administration. Specifically, the plaintiff claimed that his co-workers and managers harassed him for being Muslim after the events of 9/11. The harassment consisted of verbal taunts, intrusive searches, withholding promotions, denying him use of the bathroom, forcing him to work in substandard conditions, and having his face imposed on the body of Osama bin Laden in photos left on the plaintiff’s desk. The Court upheld a magistrate judge’s report granting the City partial summary judgment, dismissing the retaliation and failure-to-promote claims, because the Court found that the plaintiff failed to establish a prima facie case; however, the Court denied the City’s motion for summary judgment as to the hostile work environment claim, concluding that a jury could see the events as alleged to be severe and pervasive enough to allow the claim to go forward.

The Court considered questions of venue for a case related to Islamic financial instruments. The defendant, Dar al-Maal al-Islami Trust, petitioned the Court to compel the plaintiff, Vinewood Capital, to follow the arbitration clause of a profit-sharing (mudaraba) agreement. The Court determined that there was no single agreement listing both parties as signatories, and it thus refused to uphold the arbitration clause.

The defendant, Dar al-Maal al-Islami Trust, sought to enforce the terms of an arbitration clause, which required arbitration in the Bahamas upon disputes surrounding an Islamic financial profit-sharing arrangement known as a mudaraba agreement. The Court found that the clause was not enforceable, as Vinewood Capital was not a signatory party to the agreement. This decision was affirmed in 2008 by the U.S. Court of Appeals for the Fifth Circuit.

The Court denied defendant Deloitte Consulting’s summary judgment motion, contesting plaintiff Zakaria Memon’s Title VII discrimination claim against the company. The plaintiff alleged that he was given fewer assignments and ultimately fired because his religiously-mandated prayer schedule interfered with his workday and allegedly made clients uncomfortable. The defendant argued that the plaintiff was fired due to poor work performance. The Court found that the prima facie case of discrimination was strong enough to survive the motion for summary judgment, and a status and scheduling conference was set for April 2011.

Plaintiff Skwikar Abdelkader alleged a Title VII violation against her former employer, Sears, for failing to accommodate her religion (Islam). The plaintiff alleged that Sears failed to accommodate her religious beliefs by asking her for work on Fridays (the day of communal Muslim prayer services) and on Muslim holidays; she also alleged that the company retaliated against her after she reported the alleged discrimination internally to the Human Resources department. The defendant responded that they neither forced her to work those days nor punished her for refusing to do so; it further noted that she was fired because she violated company policy by allowing a cashier to use her management discount card without the direct supervision required. The Court concluded that the plaintiff failed to present a prima facie case of discrimination or retaliation, finding that the company equally punished non-Muslims for misuse of the discount card. On that basis, the Court held that no disparate treatment occurred and therefore granted the defendant’s motion for summary judgment.

The Court granted defendant Freedom Financial Network’s motion for summary judgment in a case where the plaintiff filed a complaint alleging discrimination. Following the EEOC dismissal of his claim, the Court found that the plaintiff, in his second amended complaint, still failed to state a claim warranting relief despite being given several chances to amend his complaint. Plaintiff Reginald Ringgold was an employee of defendant and claimed that he was fired because he was a Muslim and a Free Moorish American National. The defendant responded that it let the employee go because he claimed to be a tax-exempt non-citizen of the United States on several occasions, but his documentation showed that he was born in Connecticut. The Court concluded that the plaintiff failed to prove that his employer knew he was a Muslim or Free Moorish American National, and thus there was no actionable claim of discrimination.

Representing a group of Muslim truck drivers, the EEOC brought suit under Title VII against the group’s employer, Pace Services (a trucking company), alleging that the company subjected them to a hostile work environment. Specifically, the plaintiffs alleged that the company did nothing to stop their supervisor from calling them a variety of derogatory names, such as al-Qaeda, Taliban, and Osama. The company argued a recognized affirmative defense against the discrimination claim by attempting to show that it took reasonable care to prevent and promptly correct any racially-discriminatory behavior and that the employee(s) failed to take advantage of said corrections. The plaintiffs argued that the defendant could not prove the essential elements of that defense, and thus, that summary judgment should be granted in their favor. The Court dismissed the plaintiffs’ motion, concluding that the defendant had provided evidence sufficient to allow a jury to conclude that they had adequately proved the elements of the affirmative defense.

A Jordanian Muslim sued his former employer, a life insurance firm, under the California Fair Housing and Employment Act, alleging discrimination based on religion and national origin. The plaintiff argued that he was terminated from his job because he was a Muslim and of Middle Eastern origin. The defendant claimed that he was fired for failing to meet job performance standards; the plaintiff responded that the company’s explanation was a pretext, arguing that the company applied different job performance evaluation standards to him as compared to his non-Muslim co-workers. Employing the burden-shifting test established by McDonnell Douglas Corp. v. Green (where the plaintiff alleges a prima facie claim, the company responds with a reason, and the plaintiff will prevail if he can show that the reason is a pretext for actual discrimination), the Court found that the plaintiff had presented enough evidence of a discriminatory motive to establish a prima facie case and allow the suit to proceed before a jury. Accordingly, the Court denied the defendant’s motion for summary judgment.

During trial court proceedings in which a Muslim couple was dividing their marital property, the husband, Mr. Irfan Aleem, attempted to perform a “triple ṭalāq” divorce—a form of final, irrevocable dissolution of marriage under Pakistani law, initiated unilaterally by the husband. The Court refused to honor this type of divorce, concluding that it violated due process rights guaranteed by the Fourteenth Amendment by not giving Mrs. Farah Aleem any role or voice in the divorce proceedings. The Court also concluded that allowing the ṭalāq divorce to replace court proceedings was contrary to the public policy interest of the people of Maryland, as it would allow Pakistani version of Islamic law, which grants all property to the husband as the default in divorce cases, to regulate distribution of property in the state of Maryland. The Court thus upheld the ruling of the Circuit Court of Montgomery County, granting the wife’s petition for divorce, and applied the Maryland default rule that, in the absence of prior written agreement, marital property is to be divided fairly and equitably.