University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Rahim X v. Morris PC-VA-0007
Docket / Court 96-493 ( W.D. Va. )
State/Territory Virginia
Case Type(s) Prison Conditions
Case Summary
On May 23, 1996, an inmate at the Buckingham Correctional Center in Virginia filed a lawsuit under 42 U.S.C. § 1983 and the Religious Freedom Restoration Act against the Virginia Department of Corrections in the U.S. District Court for the Western District of Virginia. He alleged that his ... read more >
On May 23, 1996, an inmate at the Buckingham Correctional Center in Virginia filed a lawsuit under 42 U.S.C. § 1983 and the Religious Freedom Restoration Act against the Virginia Department of Corrections in the U.S. District Court for the Western District of Virginia. He alleged that his constitutional rights had been violated by the prison's policy that required an inmate to provide a written statement from a religious official before they would give him a religious diet. The defendant rescinded the policy and filed a motion for summary judgment.

On March 27, 1997, the U.S. District Court for the Western District of Virginia (Judge Samuel G. Wilson) granted summary judgment in favor of the prison and dismissed the prisoner's claims for declaratory and injunctive relief. The plaintiff asked the court to allow him to recover his costs from the lawsuit, arguing that the defendants had rescinded the policy as a direct result of the lawsuit. On October 27, 1997, the U.S. District Court for the Western District of Virginia (Judge Wilson) denied the inmate's motion and dismissed the case. Rahim X v. Morris 1997 WL 687729 (W.D.Va. Oct. 27, 1997).

Kristen Sagar - 03/10/2006


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Issues and Causes of Action
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Issues
General
Food service / nutrition / hydration
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) Virginia Department of Corrections
Plaintiff Description An inmate in the custody of the Virginia Department of Corrections challenging the newly-enacted policy for inmates requesting religious diets
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 None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year 1997
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)
96-493 (W.D. Va.) 07/16/2004
PC-VA-0007-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Memorandum Opinion 10/27/1997 (1997 WL 687729 / 1997 U.S.Dist.LEXIS 16690) (W.D. Va.)
PC-VA-0007-0001 PDF | WESTLAW| LEXIS | Detail
Judges Wilson, Samuel Grayson (W.D. Va.) [Magistrate]
PC-VA-0007-0001 | PC-VA-0007-9000
Monitors/Masters None on record
Plaintiff's Lawyers None on record
Defendant's Lawyers Davis, Mark Ralph (Virginia)
PC-VA-0007-9000
Other Lawyers None on record

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