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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.

The Plaintiff Nathaniel Hallman, a federal prisoner at the Lexington County Detention Center and an observing Muslim, brought this suit against the Respondents, Trinity Food Group, the Sheriff of Lexington County and several sheriff employees, for allegedly refusing to provide adequate and appropriate meals during Ramadan. The Respondents filed for summary judgment, asserting that the Ramadan meals provided to Muslim inmates were adequate. The Magistrate judge found that the prisoner requested to participate in Ramadan, during which members of the Islamic faith fasted during daylight hours. The detention center inmates observing Ramadan were not served a meal during the lunch period, but are provided a breakfast meal before sunrise and a dinner meal after sunset. The Magistrate judge recommended that the motions for summary judgment should be granted because the menu served to the inmates observing Ramadan was approved by a licensed dietician to ensure that the menu met those inmates' caloric and nutritional needs.

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.

Plaintiff Andre Harvey, a Muslim inmate at the David Wade Correctional Center, filed this action against the Respondent, Chaplain Ray Anderson, for allegedly removing the Plaintiff from the list on inmates approved to receive a religious diet and for denying him access to the Islamic community chapel. The Respondent filed a motion for summary judgment, and the Plaintiff did not file any response.  The Magistrate judge determined that the Respondent did not remove the Plaintiff from the list without cause, but instead that the Plaintiff himself failed to attend Friday prayer services and continued to not attend religious events, thereby warranting his removal from a list of Muslim inmates. The Magistrate judge therefore recommended that the motion for summary judgment be granted, and the complaint be dismissed with prejudice.

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 Daniel O’Neil Ruffin, the only practicing Muslim in the Downeast Correctional Facility in Machiasport, Maine, brought this suit against the Respondents, facility program manager Carol Geel, facility director Scott Jones, and former commissioner of the Maine Department of Corrections Martin Magnusson for allegedly violating his First Amendment rights by denying his request to be allowed to conduct religious services in the common area. The Respondents claimed that they denied the request because it would have been impracticable to assign an officer to supervise a single prisoner, and that they tried to accommodate the Plaintiff’s religious beliefs by allowing him to conduct services in his room. The Respondents filed a motion for summary judgment, which the Court referred to a Magistrate judge for a recommended decision. The Magistrate judge recommended that the Respondents be entitled to qualified immunity because a reasonable officer would not have known that the challenged conduct violated the Plaintiff’s rights.

Plaintiff Horace Crump, an inmate in the Michigan Department of Corrections, brought this compliant against the Respondent, Deputy Warden Winn at the Saginaw Correctional Facility, for changing the Muslim prayer time. Specifically, the Plaintiff alleged that the Respondent changed the Muslim prayer time in such a way as to place a substantial burden on the Plaintiff’s free exercise of his religion, and that this was done in retaliation for having complained about his and other Muslim inmates’ complaints during Ramadan. The Respondent filed a motion for summary judgment, and the case was referred for a report and recommendation by a magistrate judge. The magistrate judge determined that the Plaintiff did not suffer a substantial burden, because while the Respondent did not offer a specific penological justification for changing the prayer time, the prison immediately reinstated the religiously required Friday prayer time, such that the Plaintiff did not in fact suffer a “substantial burden” on the practice of his religion. The magistrate judge then found that the fact that the Plaintiff did not suffer a substantial burden on the practice of his religion also showed that he did not suffer adverse action, a necessary element of his retaliation claim. For these reasons, the magistrate judge recommended that the Respondent’s motion for summary judgment be granted, and that the complaint be dismissed with prejudice.

Plaintiff Abdus Shahid brought this claim against the Respondent, the Borough of Eddystone, for discrimination against him on the basis of race, national origin and religion after the Respondent deliberately engaged in a four-year-long campaign to prevent him from living in or renting out a property he owned in Eddystone because it did not want a Muslim in the area. Following the complaint, the Respondent filed a motion for summary judgment, which the District Court previously granted in part and denied in part, holding that while the Plaintiff was barred by the Heck v. Humphrey and Rooker-Feldman doctrines from challenging the validity of his convictions for violating Eddystone ordinances, there were also genuine issues of material fact that precluded summary judgment on the remaining claim that Eddystone denied him a certificate of occupancy and preventing him from renting the property because of his race, religion and national origin. Following a jury trial, the Court analyzed testimony evidence about alleged statements by Eddystone officials acknowledging the existence of a discriminatory housing policy and evidence that similarly situated white property owners were treated more favorably. However, the Court determined that the Plaintiff failed his burden of proof with regards to his claim that the Respondent violated his Fourteenth Amendment right to equal protection, because he produced no concrete credible evidence showing that he was treated differently than white property owners, and that the Respondent’s actions were anything other than genuine attempts to enforce the Eddystone housing code. The Court concluded that the Plaintiff failed to establish that the Respondent discriminated against him on the basis of race, religion or national origin. Therefore, the Court entered judgment in favor of the Respondent.

Plaintiff Kareem Hassan Milhouse, an inmate at the United States Penitentiary in Lewisburg, Pennsylvania (“USP-Lewisburg”), filed aBivens-styled complaint against several Federal Bureau of Prisons and USP-Lewisburg officials. The Plaintiff asserted that he had been denied access to the courts on three occasions and denied the practice of his religious requirements in violations of his right to free exercise, on the bases that: (1) there was no Islamic chaplain for Muslim inmates nor services for Special Management Unit inmates to attend services physically, nor were services provided through the radio as were other institutional programs, and (2) there was no Islamic celebration after the Ramadan fast, nor special meal of the types given for holidays of other faiths, and no Muslim chaplain with whom to discuss articles of faith. [He believed both of these types of services to be requirements stipulated by Islamic ritual law.] The Defendants filed a motion to dismiss and for summary judgment. The District Court granted the Defendants’ motion for summary judgment. The Court found that the alleged conduct did not fall within the scope of the Religious Freedom Restoration Act (“RFRA”), which applies to free exercise of religion claims under the First Amendment raised by prisoners, because the Plaintiff did not establish that a “substantial burden” had been placed on his ability to exercise his religion. The Court further determined that the Plaintiff had alternative means of worship available to him and that the Defendants’ conduct of providing the meal to non-Muslim inmates did not inhibit or curtail his ability to express adherence to his Islamic faith and beliefs. Because the Plaintiff failed to meet the substantial burden test with respect to both of these freedom of religion claims, the Court granted summary judgment in favor of the Defendants.

Plaintiff Jesse Copeland, an inmate of the Texas Department of Criminal Justice, brought suit after he refused to leave a Muslim religious meeting after prison officials ordered the meeting’s conclusion and was disciplined for causing a disturbance and placed on disciplinary restrictions, including a six-month ban on attending other religious meetings. The Plaintiff filed a complaint in the District Court for the Eastern District of Texas, challenging the ban and other prison policies impacting Muslim inmates. The District Court dismissed the complaint and granted summary judgment for the Respondents, prison officials at the Texas Department of Criminal Justice. The Fifth Circuit affirmed the District Court’s judgment. The Fifth Circuit determined that there was no First Amendment free exercise violation under § 1983 nor a  violation of the Plaintiff’s rights under RLUIPA based on the Plaintiff’s six-month ban from attending religious meetings due to procedural bars to the Plaintiff’s recovery, including sovereign immunity, qualified immunity, and mootness.

Plaintiff Charles Glenn, an inmate at the New Hampshire Department of Corrections (DOC) filed suit against the Respondents, various DOC prison officials, for alleged violations of his rights to free exercise [of his ability to exercise Islamic ritual law] under the First Amendment and RLUIPA. Specifically, the Plaintiff – a practicing Muslim – argued that there had been no Friday prayer (jumuʿa) services at the New Hampshire State Prison for the past three years and that he had no access to an Imam (a Muslim prayer leader), a Qur’an, or other Islamic literature, which placed constraints on his ability to practice Islam [specifically, it's ritual law aspects]. In conducting a Preliminary Review, the Court applied the four-part test for examining the constitutionality of a regulation that restricts an inmate’s First Amendment free exercise of religion found in Turner v. Safley, 482 U.S. 78, 89-90 (1987). The Court assessed the four Turner factors -- (1) whether there is a valid, rational connection between the regulation and the legitimate government interest put forward to justify it; (2) whether alternative means to exercise the right exist; (3) what impact accommodating the right will have on prison resources; and (4) whether there was an absence of alternatives to the prison regulation. The Court found that the prison’s policy of denying Friday Prayer (jumuʿa) services, which are a central and essential element of religious practice, impinged on the Plaintiff’s First Amendment right to exercise his religion.

Plaintiff Jack Robinson, a formerly incarcerated inmate at the Metropolitan Detention Center in Brooklyn (“MDC”), brought an action against Respondent, Officer Jimminez, a correctional officer at MDC, for allegedly depriving the Plaintiff of his right to religious worship under the First Amendment. The Plaintiff claimed that, although he reserved the prison’s religious room for Friday prayer (jumuʿa) services, the Respondent allowed Jewish prisoners to also use the room. The Respondent argued that the Plaintiff’s religious service was “stopped due to a scheduling conflict with another group of inmates who had also reserved the religious room for the same time as plaintiff.” The Respondent moved for summary judgment, and the district court judge referred the Respondent’s motion to a magistrate judge for a report and recommendation. The magistrate judge determined that the Respondent’s decision to stop one religious service was reasonably related to legitimate penological interests because the action was undertaken to maintain order and prevent an altercation between Muslim and Jewish prisoners, and therefore recommended that the Respondent’s motion for summary judgment be granted.

Plaintiff Derrick Lafurr Brown, a Muslim inmate confined in the Texas Department of Criminal Justice, Correctional Institutions Division, filed a suit against the Respondents, who were various prison officials at the Texas Department of Criminal Justice, for interrupting the Islamic services [Friday services specified in Islamic ritual law] out of an alleged general bias against Islam. The magistrate judge determined that the prison officials were acting in response to the Plaintiff’s repeated disobedience, and that their measure of standing in the doorway to block entry to the services was related to a legitimate penological interest and therefore did not interfere with the inmate's free exercise of religion. The magistrate judge recommended that the plaintiff's civil rights claims be dismissed without prejudice pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure.

Plaintiff Tariq A. Vaughn, Sr., an inmate at the United States Penitentiary in Lewisburg, Pennsylvania, filed a civil rights complaint pursuant to Bivens v. Six Unknown Agents of the Federal Bureau of Narcotics alleging that he told prison officials that he did not want to be housed with a Muslim inmate, and after he was placed in a cell with a Muslim inmate, that the Muslim inmate stabbed him in the head and back. The magistrate judge recommended that the Plaintiff’s civil rights complaint be dismissed with prejudice because it was frivolous, and alternatively for failing to state a claim for which relief can be granted. [There seemed to be no stated religious or Islamic law basis for the claim.]

Plaintiff Leila Diab, an observant Muslim teacher who was hired to teach social studies and English as a second language, filed a suit against the Respondents, the Chicago Board of Education and John F. Kennedy High School Principal George Szkapiak, alleging that the Respondents discriminated and retaliated against her, and further subjected her to a hostile work environment, on the basis of her Islamic faith. The Plaintiff alleged that she was forced to resign from her teaching position following anti-Islamic comments made by the principal and various teachers at the Kennedy high school. The Plaintiff further claimed that she received a hate mail note (which read: “Israel is doing OK) and that her Qur'an was desecrated on school property [in violation of norms taken to be governed by Islamic ritual law, of treating the Qur'an with respect]. In response, the Respondents filed a motion for summary judgment, seeking dismissal of the complaint. The District Court determined that in order to prevail on her discrimination claims, the Plaintiff had to show that the Respondents subjected her to an adverse employment action, such as: "(1) termination or reduction in compensation, fringe benefits, or other financial terms of employment; (2) transfers or changes in job duties that cause an employee's skills to atrophy and reduce future career prospects; and (3) unbearable changes in job conditions, such as a hostile work environment or conditions amounting to constructive discharge." Barton v. Zimmer, Inc., 662 F.3d 448, 2011 WL 4921603, at *4 (7th Cir. 2011). The Court granted the Respondent’s motion as to the Plaintiff’s hostile work environment claims, finding that it could not conclude that a reasonable jury would find the note, taken together with the Qur'an incident nine months later, to create a hostile work environment. While the Court acknowledge that the incidents may have proved upsetting to her, it observed that the two incidents were not repeated and did not involve any physical contact or verbal abuse.

Plaintiff John Knapp, a state prisoner and observant Muslim [following the general requirements of Islamic ritual law], filed suit against the Respondents, prison officials in their individual and official capacities, for an alleged violation of his rights under RLUIPA on the claim that the prison facility lacked weekly Friday prayer (jumuʿa) services. The prison employed a volunteer policy, which allowed Muslims in the prison community to volunteer to lead the Friday prayer service in order to enable group worship. But because there were no volunteers or future prospect of volunteers, the Friday prayer service was not conducted. The magistrate judge determined that the volunteer policy challenged by the Plaintiff could violate the prisoner’s rights under RLUIPA if such a policy was not the least restrictive means by which the government could achieve a compelling state interest, and that the Plaintiff’s allegations sufficed to assert a claim. The magistrate judge therefore recommended that the Plaintiff’s claim under RLUIPA be allowed to proceed.

A Uzbek alien named Yusopov, who had previously been labeled a danger to the security of the nation by the Board of Immigration Appeals, petitioned the court for asylum, withholding of removal, and relief under the Convention Against Torture. The plaintiff argued that he would likely be tortured if returned to his home country of Uzbekistan on religious and political grounds, because he was a practicing Muslim. The Court granted asylum, concluding that the government had not presented evidence to prove that the petitioner posed a national security risk. NB: The Convention Against Torture provisions on withholding removal are codified into U.S. Law at 8 C.F.R. §1206.16 (c). Further obligations noted by the Court are described in the INA at 8 U.S.C. §1231(b)(3)(A), which “prohibits removal of an individual unlawfully in this country if the Attorney General believes that the individual's life or freedom would be threatened in the country of removal on account of race, religion, nationality, membership in a particular social group, or political opinion.”

The plaintiffs were survivors, family members, and representatives of the estates of the American victims of the bombing of the U.S. Marine barracks in Beirut in 1983. The plaintiffs sued Iran, utilizing an exception to the Foreign Sovereign Immunities Act (FSIA) that allows the prosecution of foreign states that sponsor terrorism for assault, battery, intentional infliction of emotional distress, and wrongful death. The plaintiffs pointed to the financial ties between Hezbollah (who allegedly orchestrated the attack) and Iran when arguing that Iran should be held liable. Iran did not file an answer to this claim. The court entered judgment in favor of the plaintiffs, awarding $1 billion in punitive damages.