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