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Case Name Muhammad v. Coughlin JC-NY-0015
Docket / Court 91-6333 ( S.D.N.Y. )
State/Territory New York
Case Type(s) Jail Conditions
Case Summary
On September 19, 1991, an inmate member of the Nation of Islam (NOI) brought a pro se lawsuit in the U.S. District Court for the Southern District of New York, against the New York City Department of Corrections (NYC) for violations of his religious freedoms. The inmate brought suit under 42 U.S.C. ... read more >
On September 19, 1991, an inmate member of the Nation of Islam (NOI) brought a pro se lawsuit in the U.S. District Court for the Southern District of New York, against the New York City Department of Corrections (NYC) for violations of his religious freedoms. The inmate brought suit under 42 U.S.C. § 1983 alleging violations of the Religious Freedom Restoration Act (RFRA), the First Amendment, and state law. In June 1993, the court (Judge Loretta Preska) appointed a private law firm to represent the inmate. Eventually seven additional NOI followers were joined as a plaintiffs and in a second amended complaint, the inmates asked for injunctive relief ordering the defendants to recognize the NOI as a religion, to make free NOI services available to inmates, to recognize the holy days of the NOI, and to allow the NOI members to possess NOI literature that does not present a clear and present danger. The inmates also sought monetary damages. The New York State Department of Corrections (NYS) was also joined as a defendant. The defendants stipulated that any relief afforded the plaintiffs would be implemented on a system wide basis, rendering moot the need to certify a class.

Both NYC and NYS moved to dismiss the RFRA claims on the grounds that RFRA was unconstitutional. NYS, but not NYC subsequently withdrew the constitutional challenge. On June 30, 1994, the court (Judge Preska) allowed the U.S. to intervene on the question of the constitutionality of RFRA. A bench trial was held in December 1994 (the docket says a jury trial but appears to be in error, see Muhammad v. City of New York Department of Corrections, 904 F.Supp. 161, 166 (S.D.N.Y. 1995)). Prior to completion of the trial the NYS defendants settled--but the NYC defendants did not. On January 9, 1995, the court (Judge Preska) certified the settlement between the plaintiffs and NYS which included a stipulation that at the time the inmate population affiliated with the NOI exceeds 200, NYS would hire a part time NOI minister. The docket states that on April 20, 1995, the court (Judge Preska) dismissed all claims against NYS with prejudice but in a later opinion she describes the settlement as a consent decree that she approved. See Muhammad, 904 F.Supp. at 167.

On October 17, 1995, the court (Judge Preska) found that the actions of the remaining defendants did not violate the inmates' constitutional or statutory rights and that even if they did the city actors were entitled to a defense of qualified immunity. Muhammad v. City of New York Department of Corrections, 904 F.Supp. 161 (S.D.N.Y. 1995). The court found that because prisoners were offered generic Islamic services and an unlimited opportunity to meet with NOI spiritual leaders, the lack of a specific NOI service did not substantially burden the inmates' practice of religion under RFRA. The court also found that the inmates' free exercise was not substantially burdened because the NYC allowed observance of Ramadan, and breakfast and dinner were served before and after sunset in December, thereby allowing observance of the unique NOI December Fast. The court also stated that even if the inmates had been able to show a substantial burden of their free exercise, they would not prevail because all the defendants' actions were in furtherance of compelling governmental interest and were the least restrictive means. The court also found that the defendants' actions did not violate the inmates' free exercise nor amount to the establishment of religion under the First Amendment, and NYC did not discriminate against members of NOI. Finally the court found that NYC had not violated any state statutes.

The original inmate litigant appealed the denial of injunctive relief, and on September 26, 1997, the Second Circuit Court of Appeals (Judge Dennis Jacobs) held that because the inmate had been released from the NYC custody and a class was never certified, the appeal was to be dismissed as moot. Muhammad v. City of New York Department of Corrections, 126 F.3d 119 (2nd Cir. 1997).

In March 1997, inmates filed a motion in the district court for an order to enforce the 1995 settlement against NYS. NYS agreed to hire an additional NOI minister and the court ordered the plaintiff's counsel to monitor the NYS to ensure that the promise was fulfilled. The inmates then filed a motion for recovery of attorney's fees in connection with the motion to enforce. On July 9, 1998, the court (Judge Preska) found that the inmates were "prevailing parties" and that they were entitled to attorney's fees for the motion to enforce and the monitoring efforts. Muhammad v. Coughlin, No. 91 CIV. 6333(LAP), 1998 WL 382000 (S.D.N.Y. July 9, 1998). On April 27, 1999, the court (Judge Preska) approved a settlement of the inmates request for attorney's fees.

Sometime in 2001 the original inmate litigant made a motion for a hearing to reopen the decree. This is the final action listed on the PACER docket. We have no further information on this case.

Jaclyn Adams - 03/17/2006


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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. ยง 1983
Defendant(s) NYC DOC
Plaintiff Description Jail inmates and members of the Nation of Islam religion alleging violations of their rights to practice their religion
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
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 1995 - n/a
Case Closing Year n/a
Case Ongoing No
Additional Resources
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Case Studies After Decision: Implementation of Judicial Decrees in Correctional Settings
Written: Oct. 01, 1977
By: M. Kay Harris & Dudley P. Spiller (Temple University)
Citation: (1977)
[ Detail ] [ PDF ]

Docket(s)
91-6333 (S.D.N.Y.) 11/25/2002
JC-NY-0015-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Findings of Fact and Conclusions of Law 10/17/1995 (904 F.Supp. 161) (S.D.N.Y.)
JC-NY-0015-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion 09/26/1997 (126 F.3d 119)
JC-NY-0015-0002.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Memorandum and Order 07/09/1998 (1998 WL 382000 / 1998 U.S.Dist.LEXIS 10134) (S.D.N.Y.)
JC-NY-0015-0003.pdf | WESTLAW| LEXIS | Detail
Judges Jacobs, Dennis G. (Second Circuit)
JC-NY-0015-0002
Preska, Loretta A. (S.D.N.Y.)
JC-NY-0015-0001 | JC-NY-0015-0003 | JC-NY-0015-9000
Monitors/Masters None on record
Plaintiff's Lawyers Baker, Robin L. (New York)
JC-NY-0015-0001 | JC-NY-0015-0002
Bharara, Preetinder S. (New York)
JC-NY-0015-0002
Donlevy, Mary P. (New York)
JC-NY-0015-0001
Duffy, Colleen D. (New York)
JC-NY-0015-0001
Hall, W. James (New York)
JC-NY-0015-0001 | JC-NY-0015-0002
Karlan, Mitchell A. (New York)
JC-NY-0015-0001 | JC-NY-0015-0002 | JC-NY-0015-9000
Malchman, Robert E. (New York)
JC-NY-0015-0001
Moore, Leslie E. (New York)
JC-NY-0015-0002
Nam, Sue J. (New York)
JC-NY-0015-0002
Defendant's Lawyers Calhoun, Martha Anne (New York)
JC-NY-0015-0001 | JC-NY-0015-0002 | JC-NY-0015-9000
Crotty, Paul Austin (New York)
JC-NY-0015-0001 | JC-NY-0015-0002
McGrath, Stephen J. (New York)
JC-NY-0015-0002
Orsland, Chlarens (New York)
JC-NY-0015-0001
Palladino, Elisabeth A. (New York)
JC-NY-0015-9000
Payer, Cheryl (New York)
JC-NY-0015-0002
Peters, Mark G. (New York)
JC-NY-0015-9000
Other Lawyers None on record

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