University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Spratt v. Wall PC-RI-0008
Docket / Court 1:04-cv-00112-S ( D.R.I. )
State/Territory Rhode Island
Case Type(s) Prison Conditions
Case Summary
On March 31, 2004, an inmate incarcerated at the Rhode Island Department of Corrections, Adult Correctional Institutions ("ACI"), on a murder sentence filed a pro se lawsuit pursuant to 42 U.S.C. § 1983 in the U.S. District Court for Rhode Island, challenging the prison's prohibition against him ... read more >
On March 31, 2004, an inmate incarcerated at the Rhode Island Department of Corrections, Adult Correctional Institutions ("ACI"), on a murder sentence filed a pro se lawsuit pursuant to 42 U.S.C. § 1983 in the U.S. District Court for Rhode Island, challenging the prison's prohibition against him preaching at or leading religious services for other inmates. Plaintiff claimed that he engaged in preaching and religious activities from 1995 to 2003 without incident. In 2003, a new warden took over the prison and informed plaintiff that preaching was not allowed. Plaintiff alleged that the prison's actions violated his rights secured by First and Fourteenth Amendment and the Religious Land Use and Institutionalized Persons Act ("RLUIPA"), 42 U.S.C. § 2000cc.

The parties filed cross-motions for summary judgment. The magistrate judge issued a report recommending dismissal of plaintiffs First and Fourteenth Amendment claims. 2005 WL 348315 ( D.R.I. Jan. 13, 2005). Plaintiff's claims under RLUIPA were stayed pending the Supreme Court's resolution of Cutter v. Wilkinson, 544 U.S. 709, 722-24, 125 S.Ct. 2113, 161 L.Ed.2d 1020 (2005), which considered various constitutional challenges to RLUIPA.

After Cutter was decided, the magistrate judge ordered the parties to submit additional briefing as to the merits of plaintiff's RLUIPA claim. After reviewing the supplemental briefs, the magistrate judge issued a report recommending that summary judgment be entered in favor of the defendants on the RLUIPA claim. Plaintiff objected, but the District Court (Judge William E. Smith) adopted the report and recommendation. Spratt v. Wall, 2006 WL 1582402 (D.R.I. 2006). Plaintiff appealed.

On appeal, the ACLU of Rhode Island took over the handling of plaintiff's case. On April 6, 2007, the First Circuit Court of Appeals, reversed and remanded the case. Spratt v. Rhode Island Dept. of Corrections, 482 F.3d 33 (1st Cir. 2007).

In July 2007, the parties settled the case. As part of the settlement agreement, prison officials adopted a new policy that specifically authorized inmates to conduct religious sermons under the direction of an institutional chaplain. The settlement agreement also provided that defendants would pay the plaintiff's attorneys' fees. A Consent Judgment was entered by the District Court (Judge William Smith) on July 30, 2007.

Dan Dalton - 11/06/2007


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Issues and Causes of Action
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Issues
Affected Gender
Female
Male
General
Religious programs / policies
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Rhode Island Department of Corrections
Plaintiff Description Inmate legally incarcerated at the Rhode Island Department of Corrections, Cranston, Rhode Island, alleging a violation of his First and Fourteenth Amendment rights
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 2007 - n/a
Case Closing Year n/a
Case Ongoing Unknown
Additional Resources
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Case Studies Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
By: Margo Schlanger (Washington University)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
1:04-cv-00112-S (D.R.I.) 07/30/2007
PC-RI-0008-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Report and Recommendation 01/13/2005 (2005 WL 348315) (D.R.I.)
PC-RI-0008-0006 PDF | WESTLAW | Detail
Report and Recommendation 01/18/2005 (2005 WL 348314) (D.R.I.)
PC-RI-0008-0007 PDF | WESTLAW | Detail
Report and Recommendation 11/21/2005 (2005 WL 3434739) (D.R.I.)
PC-RI-0008-0008 PDF | WESTLAW | Detail
[Order] 06/06/2006 (2006 WL 1582402) (D.R.I.)
PC-RI-0008-0009 PDF | WESTLAW | Detail
News Release 06/07/2006
PC-RI-0008-0001 PDF | Detail
Document Source: Plaintiffs' counsel
[Appellate Opinion] 04/06/2007 (482 F.3d 33)
PC-RI-0008-0005 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
News Release 04/09/2007
PC-RI-0008-0002 PDF | Detail
News Release 07/30/2007
PC-RI-0008-0003 PDF | Detail
Consent Judgment 07/30/2007
PC-RI-0008-0004 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Hagopian, Jacob (D.R.I.) [Magistrate]
PC-RI-0008-0006 | PC-RI-0008-0007 | PC-RI-0008-0008
Lipez, Kermit Victor (First Circuit)
PC-RI-0008-0005
Lynch, Sandra Lea (First Circuit)
PC-RI-0008-0005
Smith, William E. (D.R.I.)
PC-RI-0008-0001 | PC-RI-0008-0003 | PC-RI-0008-0009 | PC-RI-0008-9000
Torruella, Juan R. (D.P.R., First Circuit)
PC-RI-0008-0005
Monitors/Masters None on record
Plaintiff's Lawyers Labinger, Lynette J (Rhode Island)
PC-RI-0008-0003 | PC-RI-0008-0004 | PC-RI-0008-0005 | PC-RI-0008-9000
Defendant's Lawyers Coyne-Fague, Patricia Anne (Rhode Island)
PC-RI-0008-0004 | PC-RI-0008-0005 | PC-RI-0008-0006 | PC-RI-0008-0007 | PC-RI-0008-0008 | PC-RI-0008-0009 | PC-RI-0008-9000
Other Lawyers None on record

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