University of Michigan Law School
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Case Name Gartrell v. Ashcroft PC-DC-0012
Docket / Court 01-1895 ( D.D.C. )
State/Territory District of Columbia
Case Type(s) Prison Conditions
Case Summary
Rastafarian and Muslim inmates from the District of Columbia who were housed at Virginia correctional facilities filed a class action lawsuit challenging Virginia Department of Corrections' policies prohibiting long hair or beards on inmates. The inmates were represented by Hogan and Hartson and ... read more >
Rastafarian and Muslim inmates from the District of Columbia who were housed at Virginia correctional facilities filed a class action lawsuit challenging Virginia Department of Corrections' policies prohibiting long hair or beards on inmates. The inmates were represented by Hogan and Hartson and the American Civil Liberties Union. The inmates, who sued the District of Columbia, the U.S. Attorney General, and the Federal Bureau of Prisons (BOP), alleged that the BOP's decision to house them at Virginia facilities rather than federal facilities violated the Religious Freedom Restoration Act (RFRA) and their Free Exercise of Religion because Virginia's grooming policy infringed on their religious beliefs forbidding them from cutting their hair and shaving their beards.This case was filed on September 7, 2001, but is a continuation of litigation brought against the District of Columbia in 1999, in which the BOP intervened as a defendant. The court resolved the earlier case by entering a judgment in favor of the defendants, finding that the inmates had failed to exhaust their administrative remedies as required by the Prison Litigation Reform Act. Jackson v. District of Columbia, 89 F.Supp.2d 48 (D.D.C. 2000). The court also rejected the plaintiffs' claims that the grooming policy violated RFRA or the Free Exercise Clause of the First Amendment. On appeal, the DC Circuit affirmed the judgment, agreeing that the inmates had not exhausted their administrative appeals, but vacated the portion regarding the merits of the religious claims. Jackson v. District of Columbia, 254 F.3d 262 (D.C. Cir. 2001). The inmates exhausted their administrative remedies and refiled the case in 2001.

Following a three-day bench trial, the District Court (Judge Henry H. Kennedy, Jr.) held that the inmates' sincerely held religious beliefs were burdened by the policy, that the BOP's decision to house inmates at Virginia facilities was subject to review under RFRA, and that the BOP failed to show that housing inmates at Virginia facilities was narrowly tailored to meet a compelling state interest. Gartrell v. Ashcroft, 191 F.Supp.2d 23 (D.D.C. 2002)

On February 19, 2002, Judge Kennedy issued an order granting injunctive relief to the inmates and ordering the BOP to consider each inmates' religious beliefs and practices before designating them to a Virginia prison. If an inmate's religious belief would be burdened due to their policies, that should mitigate against housing the inmate there. The court also ordered the BOP to evaluate whether the Virginia grooming policy burdened its existing inmates housed in Virginia facilities, and transfer inmates whose beliefs were so affected. The order also gave the court ongoing jurisdiction to monitor the case and ensure that the terms of the injunction were followed. The BOP appealed.

In 2003, the parties entered into a settlement on attorneys fees, which acknowledged that the BOP had been in compliance with the court's order. The BOP agreed to dismiss its appeal as part of this agreement. This agreement was approved by Judge Kennedy on February 27, 2003. On April 11, 2003, the court issued an order dismissing the case.

Denise Lieberman - 10/23/2005


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Issues and Causes of Action
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Issues
Affected Gender
Male
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)
Defendant(s) Federal Bureau of Prisons
Plaintiff Description Inmates whose avowed religious beliefs forbid them from cutting their hair or shaving their beards alleging that BOP’s housing of inmates from D.C. in Virginia DOC facilities with policy prohibiting long hair and beards burdened their religious beliefs
Indexed Lawyer Organizations None on record
Class action status sought Unknown
Class action status granted Unknown
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Settlement
Form of Settlement None on record
Order Duration 2002 - 2003
Case Closing Year 2003
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)
01-1895 (D.D.C.) 04/16/2003
PC-DC-0012-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Memorandum of Decision 03/21/2000 (89 F.Supp.2d 48) (D.D.C.)
PC-DC-0012-0002.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion 07/10/2001 (254 F.3d 262)
PC-DC-0012-0003.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Memorandum 02/19/2002 (191 F.Supp.2d 23) (D.D.C.)
PC-DC-0012-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Order 04/11/2003 (2003 WL 1873847)
PC-DC-0012-0004.pdf | WESTLAW | Detail
Judges Henderson, Karen LeCraft (D.C. Circuit, D.S.C.)
PC-DC-0012-0003
Kennedy, Henry Harold Jr. (D.D.C.) [Magistrate]
PC-DC-0012-0001 | PC-DC-0012-0002 | PC-DC-0012-9000
Rogers, John M. (Sixth Circuit)
PC-DC-0012-0003
Tatel, David S. (D.C. Circuit)
PC-DC-0012-0003
Monitors/Masters None on record
Plaintiff's Lawyers Abram, Jonathan L. (District of Columbia)
PC-DC-0012-0002 | PC-DC-0012-0003
Haft, William S. (District of Columbia)
PC-DC-0012-0003
Hogan, E. Desmond (District of Columbia)
PC-DC-0012-0001 | PC-DC-0012-0002 | PC-DC-0012-0003 | PC-DC-0012-9000
Murphy, Christopher K. (District of Columbia)
PC-DC-0012-0002
Spitzer, Arthur (District of Columbia)
PC-DC-0012-0003
Defendant's Lawyers Humphreys, Michael A. (District of Columbia)
PC-DC-0012-0001 | PC-DC-0012-0002 | PC-DC-0012-0003 | PC-DC-0012-9000
Jackson, Gregory (District of Columbia)
PC-DC-0012-0002
Lawrence, R. Craig (District of Columbia)
PC-DC-0012-0003
Lerner, Jacques Phillip (District of Columbia)
PC-DC-0012-0002
Lewis, Wilma A. (District of Columbia)
PC-DC-0012-0003
Prager, Lutz Alexander (District of Columbia)
PC-DC-0012-0003
Reischel, Charles L. (District of Columbia)
PC-DC-0012-0003
Rigsby, Robert (District of Columbia)
PC-DC-0012-0003
Schwab, Edward E. (District of Columbia)
PC-DC-0012-0003
Zane, Daria Jean (District of Columbia)
PC-DC-0012-0001 | PC-DC-0012-9000
Other Lawyers None on record

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