University of Michigan Law School
Civil Rights Litigation Clearinghouse
Pro Se prisoner's suit leads to injunction protecting Native American religious practices
September 9, 2019
On February 26, 2019, a federal district court issued a ruling in Goodman v. Davis that enjoined employees of the Texas Department of Criminal Justice from enforcing a policy that prevented prisoners from wearing long hair as required by the Native American plaintiffs’ religious beliefs. The judge found that the Department failed to support its claims that long-haired prisoners posed a security risk, especially because female prisoners were already allowed to wear long hair, and concluded that its policy violated the Religious Land Use and Institutionalized Persons Act (RLUIPA).

This case developed from a pro se plaintiff’s challenge to a number of prison rules, including ones that prevented him from smoking a prayer pipe and wearing medicine bags. While the district court (later affirmed by the Fifth Circuit) dismissed the majority of the original claims, the pro se plaintiff’s RLUIPA claim survived long enough for his case to be consolidated with similar lawsuits and for the plaintiffs to obtain pro bono counsel in 2018, six years after the litigation began.



Relevant case(s) include:

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