Filed Date: Oct. 1, 2019
Closed Date: Nov. 19, 2021
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This case is about whether a correctional facility may house an inmate in solitary confinement for refusal to cut his hair as part of the inmate's religious beliefs. This case was filed by a pre-trial detainee at the Lebanon County Correctional Facility in Pennsylvania against the facility's warden, assistant warden, and head of security on October 3, 2019. The plaintiff, filing pro se, alleged in the U.S. District Court for the Middle District of Pennsylvania that the facility's officials were violating his Eighth Amendment rights against cruel and unusual punishment by placing him in solitary confinement in retaliation for the inmate's refusal to cut his hair. The plaintiff requested that he be released from solitary confinement and placed in the facility's general population and sought punitive damages for nine months of false imprisonment. The parties consented to adjudication of the case by Magistrate Judge Joseph F. Saporito, Jr.
On December 20, 2019, the defendants moved to dismiss the case. On February 19, 2020, the plaintiff moved for a preliminary injunction. On February 20, the plaintiff, now represented by attorneys at the Pennsylvania Institutional Law Project, filed an amended complaint. The amended complaint alleged that the defendants violated the plaintiff's rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the First Amendment's Free Exercise Clause, and the Fourteenth Amendment's Due Process Clause. In addition, the amended complaint added Lebanon County as a defendant in the case. The constitutional claims were brought against all defendants, while the RLUIPA claim was brought against the individual defendants in their official capacities, as well as against Lebanon County.
The plaintiff alleged that the requirement that he remain in solitary confinement or cut off his dreadlocks imposed a substantial burden on the plaintiff's practice of his Rastafarian religious beliefs, and that the defendants' requirements were not the least restrictive means of furthering a compelling government interest. The plaintiff also alleged that the defendants inhibited his right to free exercise of religion for no legitimate penological purpose, in violation of the First Amendment, as incorporated against the states by the Fourteenth Amendment. Lastly, the plaintiff alleged that the defendants required him to stay in solitary confinement in order to punish him. The plaintiff claimed that this punishment, in light of his status as a pre-trial detainee, violated the Due Process Clause of the Fourteenth Amendment because it was not rationally related to any non-punitive government purpose or was excessive in light of any such purpose. The plaintiff requested an injunction requiring his removal from solitary confinement and release into the general population. He also requested compensatory damages, punitive damages, and attorneys' fees and costs.
On March 13, 2020, the defendants filed a renewed motion to dismiss in light of the amended complaint, seeking to dismiss the plaintiff's RLUIPA and due process claims. On April 21, the United States, through the U.S. Attorney and an Assistant U.S. Attorney for the Middle District of Pennsylvania, filed a statement of interest in the case. The statement stated that the defendants' blanket restriction of dreadlocks would not pass RLUIPA's strict scrutiny analysis based on the facts of the case presented in the parties' pleadings and briefs. The United States highlighted the exceptionally demanding standard established under RLUIPA for limits on religious practice and that the plaintiff had demonstrated a substantial burden on his religious practice. The United States also stated that the defendants were unlikely to demonstrate that the burden on the plaintiff was the least restrictive means of furthering a compelling government interest. Therefore, the United States stated that the court should find that the plaintiff had a reasonable probability of eventual success in the litigation.
On January 22, 2021, the court granted in part and denied in part the defendants' motion to dismiss the case. 2021 WL 232599. The court dismissed the plaintiff's RLUIPA claims for damages against the individual defendants in their official capacities, while allowing the RLUIPA claim for compensatory damages against the county to proceed. While the defendants claimed that monetary damages were not recoverable from any of the defendants, the court found that damages were only precluded from the individual defendants in their individual capacities. The court found that allowing the claim for damages to proceed against the county and the officials in their official capacities would be redundant, since the county would ultimately bear the costs of any damages. The court rejected the defendants' contention that the county was immune from monetary damage awards under RLUIPA, since Eleventh Amendment immunity is not available to counties.
The court also denied the defendants' motion to dismiss as to the plaintiff's substantive due process claim. The defendants moved to dismiss the claim pursuant to the "more-specific-provision rule," which states that where a particular constitutional amendment provides an explicit textual source of protection against government action, the particular amendment, rather than a generalized notion of due process, should be the guide for analyzing the claim. While the court conceded that the plaintiff's Fourteenth Amendment and First Amendment claims shared the same factual basis and arose out of the same conduct, the court found that the two claims rested on distinct legal theories. While his First Amendment claim was grounded in the plaintiff's right to free exercise of religion, the plaintiff's Fourteenth Amendment claim was based on his right to be free from punishment as a pre-trial detainee, independent from his free exercise rights.
On May 17, 2021, the parties stipulated to consolidating this case with Pratt v. Ott, No. 1:20-cv-0171, because both actions shared common issues of law and fact, pursuant to Federal Rule of Civil Procedure 42. The two cases were consolidated under No. 1:20-cv-0171.
The court entered a notice of voluntary dismissal on November 19, 2021. On January 6, 2022, the Pennsylvania Institutional Law Project announced that Lebanon County had agreed to settle with the plaintiffs in the consolidated cases for a total of $147,500. The Lebanon County Correctional Facility also agreed to eliminate its discriminatory hair policy, and will no longer prohibit people from having dreadlocks, braids, or cornrows.
This case is closed.
Summary Authors
Nicholas Gillan (11/18/2022)
Grayson Metzger (3/9/2024)
Pratt v. Ott, Middle District of Pennsylvania (2020)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/18381223/parties/mcgill-jr-v-clements/
Saporito, Joseph F. (Pennsylvania)
Feldman, Matthew A. (Pennsylvania)
Morgan-Kurtz, Alexandra T (Pennsylvania)
Clayberger, Matthew (Pennsylvania)
Morcom, Peggy M. (Pennsylvania)
See docket on RECAP: https://www.courtlistener.com/docket/18381223/mcgill-jr-v-clements/
Last updated Jan. 31, 2025, 10:40 a.m.
State / Territory: Pennsylvania
Case Type(s):
Key Dates
Filing Date: Oct. 1, 2019
Closing Date: Nov. 19, 2021
Case Ongoing: No
Plaintiffs
Plaintiff Description:
A pretrial detainee in the Lebanon County Correctional Facility
Plaintiff Type(s):
Attorney Organizations:
Pennsylvania Institutional Law Project
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Lebanon County (Lebanon), County
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Religious Freedom Rest. Act/Religious Land Use and Inst. Persons Act (RFRA/RLUIPA)
Ex parte Young (federal or state officials)
Constitutional Clause(s):
Due Process: Substantive Due Process
Available Documents:
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Amount Defendant Pays: $147,500
Issues
General/Misc.:
Discrimination Area:
Discrimination Basis:
Jails, Prisons, Detention Centers, and Other Institutions: