University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Combs v. Corrections Corp. of America PC-LA-0007
Docket / Court 95-2029 ( W.D. La. )
State/Territory Louisiana
Case Type(s) Prison Conditions
Case Summary
On November 13, 1995, seven individual inmates housed in the Winn Correctional Center near Winnfield, Louisiana filed suit in the U.S. District Court for the Western District of Louisiana, pro se, against Louisiana corrections officials for restricting their religious freedoms. The inmates alleged ... read more >
On November 13, 1995, seven individual inmates housed in the Winn Correctional Center near Winnfield, Louisiana filed suit in the U.S. District Court for the Western District of Louisiana, pro se, against Louisiana corrections officials for restricting their religious freedoms. The inmates alleged that they were denied the right to participate in Native American religious gatherings and that they were denied the use of items sacred to their religion such as pipes, feathers, drums, and a sweat lodge. The inmates claimed that these denials violated the Free Exercise Clause, the Religious Freedom Restoration Act (RFRA), the American Indian Religious Freedom Act (AIRFA), and the Indian Civil Rights Act. The inmates sought to be permitted to use their sacred items for worship, to worship during daylight hours, and to have the same amount of time to worship as other religions as well as $75,000 in compensatory damages.

After an evidentiary hearing and a Magistrates recommendation, the U.S. District Court for the Western District of Louisiana (Judge F.A. Little Jr.) found that RFRA was no longer enforceable after City of Boerne v. Flores, 521 US 507 (1997), that AIEFA did not create a cause of action, and that the Indian Civil Rights Act did not apply because it required Native American tribal governments to protect Constitutional rights. Combs v. Correction Corp. of America, 977 F.Supp. 799 (W.D. La 1997). The court determined that the defendants had not demonstrated a reasonable relation to a legitimate penological interest in restricting the practices of the Native American religion. On August 22, 1997, the court enjoined the defendants from: (1) restricting the practices of the Native American's religion to those who could demonstrate a BIA number or Native American ancestry, (2) that the plaintiffs be allowed to practice the religion at the same frequency as before the restrictive policy, and (3) that the plaintiffs be allowed to use the items needed for their ceremonies when it would not cause a security problem. The court did not grant the inmates request for a sweat lodge or damages.

On November 19, 1998, one of the inmates filed a motion to have the injunction enforced and executed alleging that the inmates were not allowed to fully perform their ceremonies and were intimidated by guards when they preformed the ceremonies and used the drums. On May 16, 2000, Judge Little ordered that: (1) the inmates be allowed to play their drums during the religious ceremonies so long as it does not impinge legitimate penological interests, (2) every effort must be made to let the plaintiffs practice their religion at the time set for practice, (3) that those persons not attending the ceremonies may be prohibited from being called out for them, (4) and that plaintiffs be encouraged to use the prisons internal procedures to help solve problems concerning the exercise of religion by Native Americans. The case was closed on June 4, 2001.

Jaclyn Adams - 02/10/2006


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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) Corrections Corporation of America
Plaintiff Description Inmates alleging limitation on inmates' participation in Native American religion
Indexed Lawyer Organizations None on record
Class action status sought Unknown
Class action status granted Unknown
Prevailing Party Mixed
Public Int. Lawyer No
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement None on record
Order Duration 1997 - 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)
95-2029 (W.D. La.) 06/04/2001
PC-LA-0007-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Ruling 08/22/1997 (977 F.Supp. 799) (W.D. La.)
PC-LA-0007-0003 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Motion to Enforce and Execute 11/19/1998
PC-LA-0007-0001 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Report and Recommendation of Magistrate Judge 04/18/2000 (W.D. La.)
PC-LA-0007-0002 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Kirk, James D. (W.D. La.) [Magistrate]
PC-LA-0007-0002 | PC-LA-0007-9000
Little, F. A. Jr. (W.D. La.)
PC-LA-0007-0003 | PC-LA-0007-9000
Monitors/Masters None on record
Plaintiff's Lawyers None on record
Defendant's Lawyers Corkern, Ronald E. Jr. (Louisiana)
PC-LA-0007-0003 | PC-LA-0007-9000
Other Lawyers None on record

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