Case: Knight v. Thompson

2:93-cv-01404 | U.S. District Court for the Middle District of Alabama

Filed Date: Nov. 24, 1993

Closed Date: 2016

Clearinghouse coding complete

Case Summary

On November 24, 1993, inmates who adhered to Native American religion filed this lawsuit in U.S. District Court for the Middle District of Alabama. The plaintiffs challenged the Alabama Department of Correction's (DOC) policies restricting Native American religious practices, including religious objects, ceremonial grounds, hair length, and sweat lodge ceremonies. The plaintiffs alleged that their First Amendment rights and the Religious Freedom Restoration Act were violated by the DOC's polic…

On November 24, 1993, inmates who adhered to Native American religion filed this lawsuit in U.S. District Court for the Middle District of Alabama. The plaintiffs challenged the Alabama Department of Correction's (DOC) policies restricting Native American religious practices, including religious objects, ceremonial grounds, hair length, and sweat lodge ceremonies. The plaintiffs alleged that their First Amendment rights and the Religious Freedom Restoration Act were violated by the DOC's policies.

Initially, the parties engaged in extensive discovery and settlement negotiations. The parties reached a stipulation in 1998 encompassing all of the plaintiffs’ claims other than the sweat-lodge claim and the hair-length claim. The DOC agreed to comply with new policies regarding ceremonial days, the ceremonial grounds, medicine bags, feathers, moccasins, prayer pipes, drums, and other religious items. In addition, the DOC agreed to provide training for correctional officers on inspection procedures and procedures for allowing inmates to retain their religious items upon transfer.

On September 10, 1999, Magistrate Judge Charles S. Coody issued a recommendation to approve the parties’ stipulation. The magistrate judge issued a separate recommendation regarding the sweat-lodge and hair-length claims and recommended the district court find in favor of the DOC on those claims. On June 12, 2000, the district court adopted both recommendations. The court retained jurisdiction over the matter for one year, while the DOC changed their policies and complied with the stipulation. The plaintiffs appealed the order as far as it entered judgment in favor of the DOC on the sweat-lodge and hair-length claims.

Meanwhile, in October 2000, a Muslim inmate filed a pro se “writ of mandamus” alleging that Muslim inmates were also being discriminated against. The district court treated the pleading as petition for intervention and denied the petition on October 31, 2000. The court stated the inmate could file a separate lawsuit in the Northern District of Alabama where his prison was located.

While the case was on appeal before the Eleventh Circuit, Congress responded to the Supreme Court's partial invalidation of the RFRA (in the City of Boerne case) by enacting the Religious Land Use and Institutionalized Persons Act (RLUIPA). Therefore, on June 12, 2001, the Eleventh Circuit remanded the case to allow the plaintiffs to amend their complaint.

On October 1, 2001, the district court granted the plaintiffs' motion to amend their complaint to include claims under RLUIPA, which they did on October 11, 2001. The parties engaged in a brief period of additional discovery.

On March 14, 2003, Magistrate Judge again recommended a grant of summary judgment on the hair-length claim, but denied summary judgment on the sweat-lodge claim. Accordingly, on September 29, 2003, the district court granted summary judgment to the defendants on their hair-length restriction claim. The plaintiffs appealed.

In December 2004, the DOC changed its policy and to permit inmates who declare Native American spirituality as their religion to participate in sweat lodge ceremonies four times a year. As a result, on September 14, 2006, the district court dismissed the sweat-lodge claims—the plaintiffs’ last remaining claim—as moot. It was undisputed that, since December 2004, sweat lodge ceremonies had been held repeatedly pursuant to the new policy. 2006 WL 2642388 (M.D.Ala., Sep. 14, 2006). The plaintiffs also appealed this order.

As an aside, five prisoners filed a motion for injunctive relief and contempt in 2007 because when they were transferred out of Alabama to a Louisiana prison, Louisiana did not allow them to practice their Native American religion. The magistrate judge recommended that their motion be transferred to the U.S. District Court for the Western District of Louisiana, and the district court adopted that recommendation on April 6, 2007. 2007 WL 1063524 (M.D.Ala., Apr. 06, 2007).

Also, in 2007, an Alabama inmate tried to intervene in the case requesting an emergency restraining order. However, on October 5, 2007, the district court denied the motion because the case was closed according to the September 13, 2006, order dismissing the plaintiffs’ final claim. 2007 WL 2926205 (M.D.Ala., Oct. 05, 2007). But the case did not stay closed.

On October 19, 2007, the Eleventh Circuit affirmed the district court’s dismissal of the sweat-lodge claims, but reversed the district court’s dismissal of the hair-length claims. The Eleventh Circuit held, per curiam, that 1) the inmate's sweat-lodge claims were moot; 2) the inmates were not entitled to monetary relief on their sweat-lodge claims; and 3) there was a genuine issue of material fact as to whether the DOC's total ban on long hair was the least restrictive means of furthering the compelling governmental interests of security, discipline, hygiene, and safety, which precluded summary judgment. The Court noted that the evidentiary record relating to the hair-length claims is over ten years old and that in the intervening time, prison staffing and administration, prison safety and security, and the prison population in Alabama had changed. Therefore, the Eleventh Circuit vacated the district court's order and remanded the case to the district court for a full evidentiary hearing and bench trial, following which the district court would make detailed findings of fact and conclusions of law. 251 F. App'x 665 (11th Cir. 2007).

On remand, Magistrate Judge Coody held an evidentiary hearing and a bench trial. Afterward, Magistrate Judge recommended judgment in favor of the DOC on the hair-length claims on July 11, 2011. 2011 WL 7477105 (M.D.Ala., July 11, 2011). On March 8, 2012, the district court adopted the magistrate judge's recommendations over the plaintiffs' objections. 2012 WL 777274 (M.D. Ala. Mar. 8, 2012). Final judgment was entered in favor of the DOC. The plaintiffs appealed, but the Eleventh Circuit affirmed on July 26, 2013. 723 F.3d 1275 (11th Cir. 2013). The plaintiffs filed a petition for certiorari and the Supreme Court granted certiorari. On January 26, 2015, the Supreme Court vacated the judgment and remanded the case for further consideration in light of Holt v. Hobbs. 135 S. Ct. 1173 (2015).

On remand, the Eleventh Circuit considered the case in light of Holt v. Hobbs, but still ended up affirming the district court’s judgment in favor of the defendants on the hair-length claim. The policy furthered compelling interests and that the policy was the least restrict means of furthering those compelling interests. 796 F.3d 1289 (11th Cir. 2015). Again, the plaintiffs petitioned for certiorari. On February 4, 2016, the petition for certiorari was docketed. On May 3, 2016, the Supreme Court denied the petition for a writ of certiorari. As of April 2019, there is no further docket activity and the case is presumably closed.

Summary Authors

Jessica Kincaid (4/9/2016)

Chiaki Nojiri (4/5/2019)

People

For PACER's information on parties and their attrorneys, see: https://www.courtlistener.com/docket/5342884/parties/knight-v-thompson-lead-case/


Judge(s)

Albritton, William Harold III (Alabama)

Carnes, Edward Earl (Alabama)

Coody, Charles S. (Alabama)

DeMent, Ira (Alabama)

Hull, Frank M. (Georgia)

Marcus, Stanley (Florida)

Propst, Robert Bruce (Alabama)

Schlesinger, Harvey Erwin (Florida)

Tjoflat, Gerald Bard (Florida)

Wilson, Charles R. (Florida)

Judge(s)

Albritton, William Harold III (Alabama)

Carnes, Edward Earl (Alabama)

Coody, Charles S. (Alabama)

DeMent, Ira (Alabama)

Hull, Frank M. (Georgia)

Marcus, Stanley (Florida)

Propst, Robert Bruce (Alabama)

Schlesinger, Harvey Erwin (Florida)

Tjoflat, Gerald Bard (Florida)

Wilson, Charles R. (Florida)

Attorneys(s) for Plaintiff

Burkhalter, Carl Stanley (Alabama)

Fruin, Peter Sean (Alabama)

Haber, Roy S. (Oregon)

Holliday, Shannon L. (Alabama)

Martin, William Preston (Alabama)

Sabel, Mark Wayne Jr. (Alabama)

Tucker, James A. (Alabama)

Attorneys(s) for Defendant

Bell, Fred Frank (Alabama)

Belser, David E. (Alabama)

Graddick, Charles A. (Alabama)

Nabors, G. Dennis (Alabama)

Steadman, Joseph David (Alabama)

Thomas, Kim Tobias (Alabama)

Other Attorney(s)

Bagenstos, Samuel R. (District of Columbia)

Byrne, Alice Ann (Alabama)

Caballero, Thomas E. (District of Columbia)

Canary, Leura Garrett (Alabama)

Clash-Drexler, Sara W. (District of Columbia)

Doyle, Stephen Michael (Alabama)

Dubois, James J. (Alabama)

Fox, Deena (District of Columbia)

Hirt, Theodore C. (District of Columbia)

Hosp, Edward Andrew (Alabama)

Keisler, Peter D. (District of Columbia)

McCallum, Robert D. Jr. (District of Columbia)

Mygatt, Timothy D (District of Columbia)

Perez, Thomas E. (District of Columbia)

Porter, John McGavock (Alabama)

Rabinovitz, Joshua Z. (District of Columbia)

Redd, Andrew Weldon (Alabama)

Rivera, Karen A. (District of Columbia)

Somerville, John Quincey (Alabama)

Vines, Kenneth E. (Alabama)

Watson, Patricia A. (Alabama)

Zimmerman, Jonathan Eli (District of Columbia)

Documents in the Clearinghouse

Document

2:93-cv-01404

Docket [PACER]

Nov. 12, 2015

Nov. 12, 2015

Docket

2:96-00554

Docket (PACER)

Native American Prisoners of Alabama − Turtle/Wind Clan v. Alabama Dept. of Corrections

May 3, 2016

May 3, 2016

Docket
193

2:93-cv-01404

Recommendation of the Magistrate Judge

Sept. 10, 1999

Sept. 10, 1999

Magistrate Report/Recommendation
214

2:93-cv-01404

Order and Judgment [Adopting Recommendations of the Magistrate Judge]

June 12, 2000

June 12, 2000

Order/Opinion
235

00-13699

Order

June 12, 2001

June 12, 2001

Order/Opinion
245

2:93-cv-01404

Order

U. S. Court of Appeals for the Eleventh Circuit

Aug. 13, 2001

Aug. 13, 2001

Order/Opinion
255

2:93-cv-01404

95-cv-00554

Order

Limbaugh v. Thompson; Native American Prisoners of Alabama v. State of Alabama Dept. of Corrections

Oct. 1, 2001

Oct. 1, 2001

Order/Opinion
255

2:93-cv-01404

Order [Granting Motion to Amend Complaint]

Oct. 1, 2001

Oct. 1, 2001

Order/Opinion
265

2:93-cv-01404

95-cv-00554

Plaintiffs' Fourth Amended Complaint, Asserting Claims Persuant to the RLUIPA

Limbaugh v. Thompson

Oct. 11, 2001

Oct. 11, 2001

Complaint
309

2:93-cv-01404

2:96-00554

Recommendation of the Magistrate Judge

Limbaugh v. Thompson

March 14, 2003

March 14, 2003

Magistrate Report/Recommendation

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/5342884/knight-v-thompson-lead-case/

Last updated Aug. 5, 2022, 3:18 a.m.

ECF Number Description Date Link Date / Link
395

RECOMMENDATION of the Magistrate Judge that: (1) to the extent the plaintiffs request injunctive and declaratory relief, the plaintiffs' claim that the ADOC's absolute prohibition of sweat lodge ceremonies is a violation of RLUIPA be dismis sed as moot; (2) to the extent the plaintiffs request damages, the plaintiffs' claim that the ADOC's absolute prohibition of sweat lodge ceremonies is a violation of RLUIPA be dismissed. Objections to R&R due by 9/19/2005. Signed by Judge Charles S. Coody on 9/6/05. (sl, )

Sept. 6, 2005

Sept. 6, 2005

RECAP
396

RECOMMEDATION of the Magistrate Judge that Irvin's 388 MOTION for Further Relief be denied. Objections to R&R due by 9/19/2005. Signed by Judge Charles S. Coody on 9/6/05. (sl, )

Sept. 6, 2005

Sept. 6, 2005

RECAP
400

ORDER ADOPTING 396 Recommendation of the Magistrate Judge and Ordered that plaintiff Irvin's Motion for Further Relief is DENIED. Signed by Judge W. Harold Albritton III on 9/21/05. (sl, )

Sept. 21, 2005

Sept. 21, 2005

RECAP
402

ORDER objections are overruled; ADOPTING 395 Report and Recommendations; 1)To the extent that the Plaintiff's request injunctive and declaratroy relief, the Plaintiffs' claim that the ADOC's absolute prohibition of sweat lodge ceremo nies is a violation of the Religious Land Use and Institutionalized Persons Act of 200)(RLUIPA), 42 USC 2000cc, et seq., is dismissed as moot; 2) To the extent that the Plaintiff's request damages, the Plaintiff's claims that the ADOC' s absolute prohibition of sweat lodge ceremonies was a violation of RLUIPA is dismissed on the basis of qualified immunity and soverign immunity as further set out. Signed by Judge W. Harold Albritton III on 9/14/06. (Attachments: # 1 appeals checklist)(vma, )

Sept. 14, 2006

Sept. 14, 2006

RECAP
427

REPORT AND RECOMMENDATIONS of the Magistrate Judge that pursuant to 28 USC 1404 the 422 MOTION for Injuctive Relief and for Contempt be transferred to the United States District Court for the Western District of Louisiana; Objections to R&R due by 4/2/2007. Signed by Judge Charles S. Coody on 3/19/2007. (wcl, )

March 19, 2007

March 19, 2007

RECAP
428

ORDER adopting the 427 Report and Recommendation of the Magistrate Judge; ORDERED that the 422 Motion for Contempt and Injunction is TRANSFERRED to the United States District Court for the Western District of Louisiana, pursuant to 28 USC 1404(a); DIRECTING the Clerk to take appropriate steps to effect the transfer. Signed by Judge W. Harold Albritton III on 4/6/2007. (Attachments: # 1 civil appeals checklist)(wcl, )

April 6, 2007

April 6, 2007

RECAP
434

ORDER directing as follows: (1) denying 432 Motion to Intervene by Malcolm S. Driskill, Jr.; (2) directing the Clerk to set up a separate lawsuit and file for the 433 Motion for Emergency Restraining Order, which will then be transferred to the appropriate district by separate Order of this court. Signed by Judge W. Harold Albritton III on 10/5/07. (Attachments: # 1 civil appeals checklist) (djy, )

Oct. 5, 2007

Oct. 5, 2007

RECAP
530

RECOMMENDATION OF THE MAGISTRATE JUDGE is as follows: 1) That the Court find that the Alabama Department of Corrections' policies restricting inmate hair length does not violate the Religious Land Use and Institutionalized Persons Act of 2000; 2) That the Court enter judgment in favor of the dfts and against the plfs; and 3) That the Court dismiss this action with prejudice; Objections to R&R due by 7/25/2011. Signed by Honorable Judge Charles S. Coody on 7/11/2011. (wcl, )

July 11, 2011

July 11, 2011

RECAP
534

ORDER granting 533 Motion for an Extension of Time to File Objections, to the extent that the time for filing objections to the Recommendation of the Magistrate Judge be and is hereby EXTENDED from 8/24/2011 until 10/24/2011; Objections to R&R due by 10/24/2011. Signed by Honorable Judge Charles S. Coody on 8/18/2011. (wcl, )

Aug. 18, 2011

Aug. 18, 2011

RECAP
541

ORDER granting 540 Motion for Extension of Time to the extent that the time for a response to the plaintiffs' objections to the recommendation of the Mag Judge be and is hereby EXTENDED from 1/27/2012 until 2/13/2012. Signed by Honorable Judge Charles S. Coody on 1/20/12. (djy, )

Jan. 20, 2012

Jan. 20, 2012

RECAP
549

ORDERED as follows: 1) Plfs' Objections are OVERRULED; 2) The 530 Recommendation of the Magistrate Judge is ADOPTED; 3) Final Judgment will be entered in favor of the Dfts and this case DISMISSED with prejudice. Signed by Honorable Judge W. Harold Albritton, III on 3/8/2012. (wcl, )

March 8, 2012

March 8, 2012

RECAP
550

FINAL JUDGMENT is entered in favor of the Dfts and against the Plfs, and this action is DISMISSED with prejudice. Signed by Honorable Judge W. Harold Albritton, III on 3/8/2012. (Attachments: # 1 Civil Appeals Checklist) (wcl, )

March 8, 2012

March 8, 2012

RECAP
580

RECOMMENDATION OF THE MAGISTRATE JUDGE that the plaintiff's supplemental motion for further relief, compliance and/or contempt (doc. # 552 ) be DENIED; further ORDERED that the parties shall file any objections to the said Recommendation on or before March 19, 2014. Signed by Honorable Judge Charles S. Coody on 3/5/14. (scn, )

March 5, 2014

March 5, 2014

RECAP
591

ORDER directing as follows: (1) Plaintiffs 585 Objections are OVERRULED; (2) The 580 Recommendation of the Magistrate Judge is ADOPTED; (3) The Supplemental Motion for Further Relief, Compliance and/or Contempt (Doc. # 552 ) is DENIED. Signed by Honorable Judge W. Harold Albritton, III on 5/30/14. (Attachments: # 1 Civil Appeals Checklist)(scn, )

May 30, 2014

May 30, 2014

RECAP

Case Details

State / Territory: Alabama

Case Type(s):

Prison Conditions

Special Collection(s):

Multi-LexSum (in sample)

Key Dates

Filing Date: Nov. 24, 1993

Closing Date: 2016

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Inmates in the Alabama Department of Corrections who practiced Native American religions

Plaintiff Type(s):

State Plaintiff

Attorney Organizations:

NDRN/Protection & Advocacy Organizations

Public Interest Lawyer: Yes

Filed Pro Se: Yes

Class Action Sought: Yes

Class Action Outcome: Mooted before ruling

Defendants

Alabama Department of Corrections, State

Defendant Type(s):

Corrections

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

Religious Freedom Rest. Act/Religious Land Use and Inst. Persons Act (RFRA/RLUIPA)

Constitutional Clause(s):

Equal Protection

Free Exercise Clause

Availably Documents:

Trial Court Docket

Complaint (any)

Injunctive (or Injunctive-like) Relief

Non-settlement Outcome

Any published opinion

U.S. Supreme Court merits opinion

Outcome

Prevailing Party: Mixed

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Litigation

Form of Settlement:

Court Approved Settlement or Consent Decree

Content of Injunction:

Provide antidiscrimination training

Training

Issues

General:

Conditions of confinement

Failure to train

Religious programs / policies

Discrimination-basis:

Religion discrimination

Race:

American Indian/Alaskan Native

Type of Facility:

Government-run