In September of 1981, three Muslim inmates at Fort Pillow State Farm filed suit in the United States District Court for the Western District of Tennessee against prison officials pursuant to 42 U.S.C. 1983 alleging that the defendants had violated their First Amendment rights. Specifically, the ...
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In September of 1981, three Muslim inmates at Fort Pillow State Farm filed suit in the United States District Court for the Western District of Tennessee against prison officials pursuant to 42 U.S.C. 1983 alleging that the defendants had violated their First Amendment rights. Specifically, the plaintiffs alleged that defendants did not allow Muslim inmates to hold religious services in the absence of an outside sponsor known as a "free world sponsor" and refused to issue name badges bearing the inmates' Muslim names. In August of 1983, another action was filed alleging that defendants failed to provide constitutionally adequate substitutes for pork and on one occasion intentionally served pork to Muslim inmates in violation of their religious tenants. Plaintiffs sought injunctive and declaratory relief and damages. In 1985 these two cases were consolidated with four other actions filed by Muslim inmates in the Western District of Tennessee.
In 1985 the district court (Judge Robert McRae) granted injunctive relief requiring defendants to accommodate Muslim inmates in terms of the food served at the prison, to allow for religious services even in the absence of a "free world sponsor," and to change prison records upon request to reflect the inmates' Muslim names. The district court also denied plaintiffs' request for damages. Defendants appealed the injunctive relief issued by the district court, and one plaintiff cross-appealed the court's decision to deny money damages.
On May 31, 1991, the Sixth Circuit Court of Appeals (per curiam opinion by Judges Keith Nelson, David A. Nelson, and John W. Peck) affirmed the lower court's denial of monetary relief but found that the scope of the court's injunction reached too broadly. Shabazz v. Norris, No. 89-6145, 89-6149, 1991 U.S. Ct. App. WL 90894 (6th Cir. May 31, 1991). The court held that defendants did not have to change their menu plans, because plaintiffs failed to establish any right to relief based upon their claims that their rights had been violated by the prison's food and menu practices. The court also held that defendants could require a "free world sponsor" but only if the requirement was applied in a neutral manner to all religious gatherings. Finally, the court stated that the district court did not order defendants to change prison records to reflect inmates' Muslim names, but only observed that it would be proper and appropriate to do so; therefore, the court found there was no issue to appeal concerning the recognition of Muslim names.Emilee Baker - 05/17/2006