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Case Name Crawford v. Clark PC-MA-0035
Docket / Court 1:01-cv-12145 ( D. Mass. )
State/Territory Massachusetts
Case Type(s) Prison Conditions
Case Summary
This action began with a pro se complaint filed in 2001 by prison inmates in the custody of the Massachusetts Department of Correction (the "DOC"). Plaintiffs brought the action against the Commissioner of DOC and other DOC defendants under 42 U.S.C. § 1983 in the U.S. District Court for the ... read more >
This action began with a pro se complaint filed in 2001 by prison inmates in the custody of the Massachusetts Department of Correction (the "DOC"). Plaintiffs brought the action against the Commissioner of DOC and other DOC defendants under 42 U.S.C. § 1983 in the U.S. District Court for the District of Massachusetts, Boston Division. Plaintiffs were Muslims and members of the Nation of Islam. Plaintiffs alleged that Defendants had interfered with their right to freely exercise their religion and had denied them an opportunity to exercise their religion equal to that of inmates of other faiths who were confined to the DOC facilities. Plaintiffs sought declaratory and injunctive relief for the deprivation of their rights as secured by the First and Fourteenth Amendment to the Constitution, laws and regulations of the United States and the Commonwealth of Massachusetts.

On March 29, 2004, the court entered an order denying Plaintiffs' request for interim injunctive relief. On May 12, 2004, Defendants filed a motion for summary judgment. On July 23, 2004, the court issued a Memorandum and Order finding Defendants exempted by qualified and official immunity from any claims for monetary damages. The court further determined that Plaintiffs were not entitled to relief as a matter of law with regard to DOC's ban on prayer rugs or its policy of assigning prisoners to kitchen service jobs on a nondiscriminatory basis. However, the court found that a triable issue of fact existed as to whether DOC's refusal to provide Halal meals to Muslim inmates constituted an undue burden on Plaintiffs' exercise of their religious beliefs. The court then appointed counsel to represent Plaintiffs. Newly appointed counsel thereafter, on May 26, 2005, filed an Amended Complaint.

On April 14, 2006, Plaintiffs filed a motion urging the court to revisit the prayer rug issue based on "newly discovered" evidence. After a hearing, on August 31, 2006, the court granted Plaintiffs' motion for reconsideration, thereby framing the three issues to be decided at trial: whether DOC's refusal to provide regular Halal meals, its ban on traditional prayer rugs, and its refusal to permit inmates to participate in Jum'ah services, substantially and unjustifiably burdened Plaintiffs' exercise of their religious rights. In January of 2007, a six-day non-jury trial was held. Final arguments were heard in February of 2007. The parties were then given leave to file further pleadings.

At the close of Plaintiffs' case, the Commissioner filed a motion for judgment on partial findings, arguing that all but one (the Halal meal issue) of Plaintiffs' three claims were barred by the Prison Litigation Reform Act, 42 U.S.C. § 1997(e) (PLRA). The court provisionally denied the motion, but deferred a final ruling until after the close of evidence and an opportunity for Plaintiffs to reply to the newly asserted jurisdictional claim.

On March 05, 2008, the court entered an order denying the Commissioner's motion for judgment on partial findings. In the order, the court granted Plaintiffs' request for declaratory and injunctive relief on the issues of Halal meals and closed-circuit television access to Jum'ah services. However, the court held DOC's practice of providing Plaintiffs with prayer towels in lieu of prayer rugs did not create a substantial burden on Plaintiffs' religious beliefs. No money damages were awarded. A final judgment was entered on April 11, 2008.

Defendants appealed to the First Circuit. On August 24, 2009, in a published opinion, the Court of Appeals affirmed the district court's entry of the injunction.

Xin Chen - 05/29/2011


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Issues and Causes of Action
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Issues
General
Religious programs / policies
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action Religious Freedom Rest. Act/Religious Land Use and Inst. Persons Act (RFRA/RLUIPA)
42 U.S.C. § 1983
Defendant(s) Commissioner of the Department of Corrections in the Commonwealth of Massachusetts
Plaintiff Description Plaintiffs are Muslims and members of the Nation of Islam in the custody of the Massachusetts Department of Corrections. he “DOC”).
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 Litigation
Form of Settlement None on record
Order Duration 2008 - n/a
Case Closing Year 2008
Case Ongoing No
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)
1:01-cv-12145 (D. Mass.) 10/22/2009
PC-MA-0035-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Plaintiff's Verified Complaint for Class Action 08/05/2002
PC-MA-0035-0001 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum and Order on Plaintiffs' Motion for a Preliminary Injunction 03/30/2004 (2004 WL 626814) (D. Mass.)
PC-MA-0035-0002 PDF | WESTLAW | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Defendants' Memorandum of Law in Support of Their Motion for Summary Judgment 05/12/2004
PC-MA-0035-0003 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum and Order on Defendants' Motion for Summary Judgment 07/23/2004 (326 F.Supp.2d 206) (D. Mass.)
PC-MA-0035-0004 PDF | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
First Amended Complaint 07/23/2004 (D. Mass.)
PC-MA-0035-0005 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Plaintiffs' Trial Brief 01/07/2007
PC-MA-0035-0006 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum of Law in Support of Defendant's Motion for Judgment on Partial Findings 01/18/2007
PC-MA-0035-0013 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Findings of Fact, Rulings of Law, and Order after a Non-Jury Trial 03/05/2008 (538 F.Supp.2d 400) (D. Mass.)
PC-MA-0035-0007 PDF | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Final Judgment 04/11/2008 (2008 WL 1451984) (D. Mass.)
PC-MA-0035-0008 PDF | WESTLAW | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum and Order on Plaintiffs’ Motion for Attorneys' Fees and Costs 07/25/2008 (568 F.Supp.2d 125) (D. Mass.)
PC-MA-0035-0009 PDF | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Brief of Defendant-Appellant Clarke 02/03/2009
PC-MA-0035-0010 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Brief of Plaintiffs-Appellees 02/23/2009
PC-MA-0035-0011 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
First Circuit Opinion 08/24/2009 (578 F.3d 39)
PC-MA-0035-0012 PDF | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Stearns, Richard Gaylore (D. Mass.)
PC-MA-0035-0002 | PC-MA-0035-0004 | PC-MA-0035-0007 | PC-MA-0035-0008 | PC-MA-0035-0009 | PC-MA-0035-9000 | PC-MA-0035-9000
Torruella, Juan R. (D.P.R., First Circuit)
PC-MA-0035-0012
Monitors/Masters None on record
Plaintiff's Lawyers Gacioch, David Q. (Massachusetts)
PC-MA-0035-0011 | PC-MA-0035-9000
Goldberger, Benjamin A. (Massachusetts)
PC-MA-0035-0005 | PC-MA-0035-0006 | PC-MA-0035-9000
Kendall, Michael (Massachusetts)
PC-MA-0035-0006 | PC-MA-0035-0011 | PC-MA-0035-9000
Marcellino, James J. (Massachusetts)
PC-MA-0035-9000
Minahan, Neal E. Jr. (Massachusetts)
PC-MA-0035-0006 | PC-MA-0035-0011 | PC-MA-0035-9000
Defendant's Lawyers Anderson, Charles W Jr. (Massachusetts)
PC-MA-0035-9000
Eiro-Bartevyan, Mary C. (Massachusetts)
PC-MA-0035-9000
McFarland, Richard C. (Massachusetts)
PC-MA-0035-0010 | PC-MA-0035-0013 | PC-MA-0035-9000
White, Nancy Ankers (Massachusetts)
PC-MA-0035-0003 | PC-MA-0035-9000
Other Lawyers None on record

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