Case: Pratt v. Ott

1:20-cv-00171 | U.S. District Court for the Middle District of Pennsylvania

Filed Date: Jan. 31, 2020

Closed Date: Nov. 22, 2021

Clearinghouse coding complete

Case Summary

On February 4, 2020, a person in pretrial detention at the Lebanon County Correctional Facility (LCCF) in Pennsylvania filed a lawsuit pro se in the U.S. District Court for the Middle District of Pennsylvania against LCCF personnel and Lebanon County. The plaintiff alleged that he was placed in administrative segregation for refusing to cut off his dreadlocks in accordance with his Rastafarian faith. The case was initially assigned to Judge Jennifer P. Wilson, and was reassigned to Chief Judge …

On February 4, 2020, a person in pretrial detention at the Lebanon County Correctional Facility (LCCF) in Pennsylvania filed a lawsuit pro se in the U.S. District Court for the Middle District of Pennsylvania against LCCF personnel and Lebanon County. The plaintiff alleged that he was placed in administrative segregation for refusing to cut off his dreadlocks in accordance with his Rastafarian faith. The case was initially assigned to Judge Jennifer P. Wilson, and was reassigned to Chief Judge Christopher C. Conner on March 31, 2020.

On May 22, 2020, the original plaintiff and a similarly situated incarcerated individual filed an amended complaint, now represented by the Pennsylvania Institutional Law Project. According to the amended complaint, prior to April 23, 2020, LCCF rules and regulations did not explicitly prohibit incarcerated individuals from having dreadlocks. However, the plaintiffs alleged that LCCF maintained a policy, practice, or custom of punishing incarcerated individuals who refused to cut off their dreadlocks by placing them in solitary confinement for months while permitting white incarcerated individuals to have other forms of long hair. Neither plaintiff was given the opportunity to contest their placement in solitary confinement. On April 23, 2020, LCCF amended its hairstyle policy to explicitly prohibit dreadlocks, but allowed incarcerated individuals to request an exemption if they had “sincerely held religious beliefs requiring them to wear their hair in a style otherwise prohibited” under the new policy.

The plaintiffs alleged violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA), as well as violations of the Free Exercise Clause of the First Amendment and the Due Process and Equal Protection Clauses of the Fourteenth Amendment. The plaintiffs sought declaratory and injunctive relief, compensatory and punitive damages, and attorneys’ fees and costs.

On July 27, 2020, LCCF moved to dismiss three of the plaintiffs’ four claims for failure to state a claim. First, LCCF argued that, because it amended its hairstyle policy to include a religious exemption, and because the plaintiffs had since been released and thus no longer sought injunctive relief, the plaintiffs’ RLUIPA claim was moot. LCCF also argued that RLUIPA’s governmental-discretion provision enabled it to avoid all liability—including damages—by amending the challenged policy. Second, LCCF moved to dismiss the plainitffs’ substantive due process claim under the more-specific-provision rule, which requires a court to analyze a constitutional claim covered by a specific constitutional provision under the standards of that provision—in this case, the Free Exercise Clause—rather than under substantive due process standards. Third, LCCF argued that the plaintiffs failed to allege a race discrimination claim under the Equal Protection Clause. In a March 31, 2021 opinion, the court rejected all three of LCCF’s claims. First, the court found that amendments to challenged policies did not moot claims for compensatory damages and attorneys’ fees under RLUIPA. The court also found that the governmental-discretion provision only dealt with preemption. Next, the court refused to dismiss the plaintiffs’ substantive due process claim, finding that the plaintiffs’ claim under the Free Exercise Clause was distinct and not more specific than the plaintiffs’ claim under the Due Process Clause. Finally, the court found that the plaintiffs clearly alleged that LCCF’s hairstyle policy was applied differently on the basis of race. 2021 WL 1212587. 

On June 7, 2021, the court consolidated McGill, Jr. v. Clements with the present case for the purposes of discovery. On November 19, 2021, the plaintiffs voluntarily moved to dismiss this case. 

On January 6, 2022, the Pennsylvania Institutional Law Project announced that a settlement agreement had been reached between the two plaintiffs in the present case as well as the plaintiff in McGill, with LCCF agreeing to eliminate the discriminatory hair policy and pay a total of $147,500. Under the agreement, LCCF agreed to no longer prohibit braids, cornrows, or dreadlocks, regardless of a person’s religious beliefs.

This case is now closed.

Summary Authors

Saba Khan (5/19/2023)

Related Cases

McGill, Jr. v. Clements, Middle District of Pennsylvania (2019)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/18381827/parties/pratt-v-ott/


Judge(s)

Conner, Christopher C. (Pennsylvania)

Attorney for Plaintiff

Feldman, Matthew A. (Pennsylvania)

Morgan-Kurtz, Alexandra T (Pennsylvania)

Attorney for Defendant

Clayberger, Matthew (Pennsylvania)

show all people

Documents in the Clearinghouse

Document
1

1:20-cv-00171

Civil Complaint

Feb. 4, 2020

Feb. 4, 2020

Complaint
22

1:20-cv-00171

Amended Complaint

May 22, 2020

May 22, 2020

Complaint
38

1:20-cv-00171

MEMORANDUM

March 31, 2021

March 31, 2021

Pleading / Motion / Brief

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/18381827/pratt-v-ott/

Last updated March 9, 2024, 3:08 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against All Defendants lodged pending the disposition of the Motion to Proceed In Forma Pauperis, filed by Leonttayy Amir Pratt.(lp) (Entered: 02/04/2020)

Feb. 4, 2020

Feb. 4, 2020

Clearinghouse
2

Application to proceed in forma pauperis by Leonttayy Amir Pratt.. (lp) (Entered: 02/04/2020)

Feb. 4, 2020

Feb. 4, 2020

PACER
3

PRISONER AUTHORIZATION by Leonttayy Amir Pratt allowing prison to submit copy of prisoner's trust fund account to the court, and approving the entire filing fee to be deducted from prisoner inmate account.. (lp) (Entered: 02/04/2020)

Feb. 4, 2020

Feb. 4, 2020

PACER
4

U.S. MARSHAL - 285, AO 398 and AO 399 Service Forms Completed by Plaintiff. (lp) (Entered: 02/04/2020)

Feb. 4, 2020

Feb. 4, 2020

PACER
5

PRO SE LETTER ISSUED w/ Notice & Consent Form. (Attachments: # 1 Notice of Consent) (lp) (Entered: 02/04/2020)

Feb. 4, 2020

Feb. 4, 2020

PACER
6

STANDING PRACTICE ORDER Signed on 02/08/2011. (Attachments: # 1 0285)(lp) (Entered: 02/04/2020)

Feb. 4, 2020

Feb. 4, 2020

PACER
7

THIRTY (30) DAY ADMINISTRATIVE ORDER directing the prisoner to pay the filing fee or file a signed Application to Proceed IFP within 30 days or case will be dismissed. Signed by LP on 02/04/2020. (Attachments: # 1 IFP (civil rights))(lp) (Entered: 02/04/2020)

Feb. 4, 2020

Feb. 4, 2020

PACER
8

U.S. MARSHAL - 285 Service Forms Completed by Plaintiff. (ao) (Entered: 02/10/2020)

Feb. 10, 2020

Feb. 10, 2020

PACER
9

MOTION (Application) for Leave to Proceed in forma pauperis by Leonttayy Amir Pratt.(ao) (Entered: 02/10/2020)

Feb. 10, 2020

Feb. 10, 2020

PACER
10

FIFTEEN (15) DAY ADMINISTRATIVE ORDER - Within 15 days of the date of this Order, the superintendent or warden of the institution at which Plaintiff is currently incarcerated is directed to provide certified copies of the statement of Pltf's trust fund account to this Court and to the Plaintiff. The statement should reflect all activity in that account for the six-month period immediately preceding the lodging of the complaint in this action. Order sent to Superintendent and plaintiff. Signed by LP on 03/04/2020. (lp) Modified on 3/4/2020 (lp). (Entered: 03/04/2020)

March 4, 2020

March 4, 2020

PACER
11

CERTIFIED Prisoner Trust Fund Account Statement of Leonttayy Amir Pratt. (ao) Modified on 3/20/2020 (lp). (Entered: 03/18/2020)

March 18, 2020

March 18, 2020

PACER
12

NOTICE of Appearance by Matthew A. Feldman on behalf of Leonttayy Amir Pratt. (Feldman, Matthew) (Entered: 03/19/2020)

March 19, 2020

March 19, 2020

PACER
13

NOTICE of Appearance by Alexandra T Morgan-Kurtz on behalf of Leonttayy Amir Pratt (Morgan-Kurtz, Alexandra) (Entered: 03/25/2020)

March 25, 2020

March 25, 2020

PACER
14

ORDER DIRECTING THE CLERK'S OFFICE TO SEND AO 398 AND 399 WAIVERS FORMS to defendants. IT IS ORDERED that Plaintiffs application for leave to proceed IFP 9, is GRANTED; The Clerk of Court is DIRECTED to send a copy of this order to the Superintendent/Warden of the institution where Plaintiff is presently confined. The complaint is DEEMED filed. The Clerk of Court is directed to SERVE a copy of the complaint 1, notice of lawsuit and request to waive service of summons (form AO 398), waiver of the service of summons (form AO 399), and this order on the named defendants. Signed by Honorable Jennifer P. Wilson on 3/27/20. (rw) (Additional attachment(s) added on 3/27/2020: # 1 Mailing Labels) (rw). (Entered: 03/27/2020)

March 27, 2020

March 27, 2020

PACER
15

Waiver of Service forms (AO 398 and 399) Mailed to Michael Ott, Tina Litz, and Robert J. Karnes, Waiver of Service due by 4/27/2020. (rw) (Entered: 03/27/2020)

March 27, 2020

March 27, 2020

PACER

ORDER REASSIGNING CASE - Case reassigned to Chief Judge Christopher C. Conner for all further proceedings. (jw)

March 31, 2020

March 31, 2020

PACER
16

NOTICE of Appearance by Matthew Clayberger on behalf of All Defendants (Clayberger, Matthew) (Entered: 04/27/2020)

April 27, 2020

April 27, 2020

PACER
17

WAIVER OF SERVICE Returned by Robert J. Karnes. Robert J. Karnes waiver sent on 3/27/2020, answer due 5/26/2020. (Clayberger, Matthew) (Entered: 04/27/2020)

April 27, 2020

April 27, 2020

PACER
18

WAIVER OF SERVICE Returned by Tina Litz. Tina Litz waiver sent on 3/27/2020, answer due 5/26/2020. (Clayberger, Matthew) (Entered: 04/27/2020)

April 27, 2020

April 27, 2020

PACER
19

WAIVER OF SERVICE Returned by Michael Ott. Michael Ott waiver sent on 3/27/2020, answer due 5/26/2020. (Clayberger, Matthew) (Entered: 04/27/2020)

April 27, 2020

April 27, 2020

PACER
20

Unopposed MOTION for Leave to File Amended Complaint by Leonttayy Amir Pratt. (Attachments: # 1 Exhibit(s) Amended Complaint, # 2 Proposed Order)(Morgan-Kurtz, Alexandra) (Entered: 05/21/2020)

May 21, 2020

May 21, 2020

PACER
21

ORDERED that Plaintiffs' Motion for Leave to File Amended Complaint, 20 is GRANTED. The Clerk of Court is directed to docket the proposed amended complaint, Doc. 20-1, as a new and separate entry on the docket. Signed by Chief Judge Christopher C. Conner on 5/22/2020 (ktt) (Entered: 05/22/2020)

May 22, 2020

May 22, 2020

PACER
22

AMENDED COMPLAINT against All Defendants filed by Leonttayy Amir Pratt, Lamont Robinson.(ktt) (Entered: 05/22/2020)

May 22, 2020

May 22, 2020

Clearinghouse
23

Summons Issued as to Lebanon County, Joseph Wheeler and provided TO ATTORNEY ELECTRONICALLY VIA ECF for service on Defendant(s)in the manner prescribed by Rule 4 of the Federal Rules of Civil Procedure. (NOTICE TO ATTORNEYS RECEIVING THE SUMMONS ELECTRONICALLY: You must print the summons and the attachment when you receive it in your e-mail and serve them with the complaint on all defendants in the manner prescribed by Rule 4 of the Federal Rules of Civil Procedure). (Attachments: # 1 AO 398 and 399 Waiver Forms, # 2 Waiver Notice) (ktt) (Entered: 05/22/2020)

May 22, 2020

May 22, 2020

PACER
24

WAIVER OF SERVICE Returned by Robert J. Karnes, Lebanon County, Tina Litz, Joseph Wheeler, Michael Ott. Joseph Wheeler waiver sent on 6/10/2020, answer due 8/10/2020. (Clayberger, Matthew) (Entered: 06/10/2020)

June 10, 2020

June 10, 2020

PACER
25

WAIVER OF SERVICE Returned by Robert J. Karnes, Lebanon County, Tina Litz, Joseph Wheeler, Michael Ott. Lebanon County waiver sent on 6/10/2020, answer due 8/10/2020. (Clayberger, Matthew) (Entered: 06/10/2020)

June 10, 2020

June 10, 2020

PACER
26

MOTION for Extension of Time to to Respond to Plaintiffs' Amended Complaint by Robert J. Karnes, Lebanon County, Tina Litz, Michael Ott, Joseph Wheeler.(Clayberger, Matthew) (Entered: 06/10/2020)

June 10, 2020

June 10, 2020

PACER
27

ORDER - IT IS HEREBY ORDERED that: 1. Defendants' unopposed motion for an extension of time 26 is GRANTED. 2. Defendants shall respond to the amended complaint by July 27, 2020. Signed by Honorable Christopher C. Conner on 6/19/2020 (ktt) (Entered: 06/19/2020)

June 19, 2020

June 19, 2020

PACER
28

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Robert J. Karnes, Lebanon County, Tina Litz, Michael Ott, Joseph Wheeler. (Attachments: # 1 Exhibit(s) A, # 2 Proposed Order)(Clayberger, Matthew) (Entered: 07/27/2020)

July 27, 2020

July 27, 2020

PACER
29

BRIEF IN SUPPORT re 28 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Robert J. Karnes, Lebanon County, Tina Litz, Michael Ott, Joseph Wheeler.(Clayberger, Matthew) (Entered: 07/27/2020)

July 27, 2020

July 27, 2020

PACER
30

Unopposed MOTION for Extension of Time to Respond to Defendants' Motion to Dismiss by Leonttayy Amir Pratt, Lamont Robinson. (Attachments: # 1 Proposed Order)(Feldman, Matthew) (Entered: 08/04/2020)

Aug. 4, 2020

Aug. 4, 2020

PACER
31

ORDER granting 30 Motion to Extend Time. Signed by Honorable Christopher C. Conner on 8/5/2020 (ktt) (Entered: 08/05/2020)

Aug. 5, 2020

Aug. 5, 2020

PACER
32

MOTION to Exceed Page Limitation by Leonttayy Amir Pratt, Lamont Robinson. (Attachments: # 1 Proposed Order)(Morgan-Kurtz, Alexandra) (Entered: 08/20/2020)

Aug. 20, 2020

Aug. 20, 2020

PACER
33

ORDER granting 32 Motion for Leave to File Excess Pages. Signed by Honorable Christopher C. Conner on 8/21/2020 (ve) (Entered: 08/21/2020)

Aug. 21, 2020

Aug. 21, 2020

PACER
34

BRIEF IN OPPOSITION re 28 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Leonttayy Amir Pratt, Lamont Robinson. (Attachments: # 1 Proposed Order, # 2 Unpublished Opinion(s), # 3 Unpublished Opinion(s), # 4 Unpublished Opinion(s), # 5 Unpublished Opinion(s), # 6 Unpublished Opinion(s), # 7 Unpublished Opinion(s), # 8 Unpublished Opinion(s), # 9 Unpublished Opinion(s))(Feldman, Matthew) (Entered: 08/24/2020)

Aug. 24, 2020

Aug. 24, 2020

RECAP
35

Unopposed MOTION for Extension of Time to File Reply Brief in Support of Their Motion to Dismiss by Robert J. Karnes, Lebanon County, Tina Litz, Michael Ott, Joseph Wheeler. (Attachments: # 1 Proposed Order)(Clayberger, Matthew) (Entered: 08/28/2020)

Aug. 28, 2020

Aug. 28, 2020

PACER
36

REPLY BRIEF re 28 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Robert J. Karnes, Lebanon County, Tina Litz, Michael Ott, Joseph Wheeler.(Clayberger, Matthew) (Entered: 09/09/2020)

Sept. 9, 2020

Sept. 9, 2020

PACER
37

ORDER granting 35 Motion to Extend Time. Signed by Honorable Christopher C. Conner on 10/22/2020. (spm) (Entered: 10/22/2020)

Oct. 22, 2020

Oct. 22, 2020

PACER
38

MEMORANDUM (Order to follow as separate docket entry). Signed by Honorable Christopher C. Conner on 3/31/2021. (mw) (Entered: 03/31/2021)

March 31, 2021

March 31, 2021

Clearinghouse
39

ORDER (memorandum filed previously as separate docket entry) - it is hereby ORDERED that defendants motion (Doc. 28 ) to dismiss is DENIED and defendants shall respond to plaintiffs amended complaint in accordance with the Federal Rules of Civil Procedure. Signed by Honorable Christopher C. Conner on 3/31/2021. (mw) (Entered: 03/31/2021)

March 31, 2021

March 31, 2021

RECAP
40

ANSWER to 22 Amended Complaint by Robert J. Karnes, Lebanon County, Tina Litz, Michael Ott, Joseph Wheeler.(Clayberger, Matthew) (Entered: 04/07/2021)

April 7, 2021

April 7, 2021

PACER
41

SCHEDULING ORDER: Case Management Conference set for 6/18/2021 at 10:15 AM before Honorable Christopher C. Conner. Signed by Honorable Christopher C. Conner on 5/3/2021. (Attachments: # 1 Term. Calendar)(mw) (Entered: 05/03/2021)

May 3, 2021

May 3, 2021

PACER
42

VERBAL ORDER It is ORDERED that the case management conference scheduled for Friday, June 18, 2021, is RESCHEDULED to Monday, June 14, 2021, at 10:15 a.m. All other aspects of the courts case management conference scheduling order shall remain in full force and effect. (Text-only entry; no PDF document will issue. This text-only entry constitutes the order of the court or notice on the matter.) Signed by Honorable Christopher C. Conner on 5/12/2021. (mw) (Entered: 05/12/2021)

May 12, 2021

May 12, 2021

PACER
43

Joint MOTION to Consolidate Cases by Leonttayy Amir Pratt, Lamont Robinson. (Attachments: # 1 Proposed Order)(Feldman, Matthew) (Entered: 05/17/2021)

May 17, 2021

May 17, 2021

PACER
44

ORDER: 1. A telephonic conference concerning the Joint MOTION to Consolidate Cases 43 shall commence at 11:30 a.m. on 6/4/21.2. Counsel for pltfs shall initiate the call to chambers at 717-221-3945. At the time the call is placed, all counsel shall be on the line and prepared to proceed. Signed by Honorable Christopher C. Conner on 5/28/21. (ma) (Entered: 05/28/2021)

May 28, 2021

May 28, 2021

PACER
46

ORDER REFERRING CASE for Settlement to Magistrate Judge Martin C. Carlson. Signed by Honorable Christopher C. Conner on 6/4/21. (ma) (Entered: 06/04/2021)

June 4, 2021

June 4, 2021

PACER
47

VERBAL ORDER - It is ORDERED that the case management conference scheduled for June 14, 2021, is CANCELLED and will be rescheduled if necessary following the settlement conference to be scheduled before Magistrate Judge Carlson. (Text-only entry; no PDF document will issue. This text-only entry constitutes the order of the court or notice on the matter.) Signed by Honorable Christopher C. Conner on 6/4/21. (spm) (Entered: 06/04/2021)

June 4, 2021

June 4, 2021

PACER
48

Joint MOTION to Consolidate Cases (Amended) by Leonttayy Amir Pratt, Lamont Robinson. (Attachments: # 1 Proposed Order)(Feldman, Matthew) (Entered: 06/07/2021)

June 7, 2021

June 7, 2021

PACER
49

ORDER - IT IS ORDERED that 3:19-cv-1712 and 1:20-cv-171 are consolidated for purposes of discovery only. The Clerk of Court shall refer the matter docketed at 1:20-cv-171 to MJ Saporito for consolidated discovery management. 48 Signed by Honorable Christopher C. Conner on 6/7/2021. (sc) (Entered: 06/07/2021)

June 7, 2021

June 7, 2021

PACER
50

SCHEDULING ORDER - A Settlement Conference set for 7/20/2020 at 1:00 PM via ZOOM before Magistrate Judge Martin C. Carlson. Signed by Magistrate Judge Martin C. Carlson on June 15, 2021. (kjn) (Entered: 06/15/2021)

June 15, 2021

June 15, 2021

PACER
52

ORDER - IT IS ORDERED that the parties provide a status report on their discussions, including any recommendations regarding the scheduling of further settlement conferences, on or before August 20, 2021. Signed by Magistrate Judge Martin C. Carlson on August 5, 2021. (kjn) (Entered: 08/05/2021)

Aug. 5, 2021

Aug. 5, 2021

PACER
53

SCHEDULING ORDER - A Settlement Conference set for 9/17/2021 at 1:00 PM via ZOOM before Magistrate Judge Martin C. Carlson. Signed by Magistrate Judge Martin C. Carlson on August 20, 2021. (kjn) (Entered: 08/20/2021)

Aug. 20, 2021

Aug. 20, 2021

PACER
54

ORDER - it is hereby ORDERED that the Clerk of Court is directed to mark this matter CLOSED for statistical purposes only and the partiesshall, as soon as practicable, submit an appropriate dismissal filing in accordance with Federal Rule of Civil Procedure. Signed by Honorable Christopher C. Conner on 9/20/2021. (mw) (Entered: 09/20/2021)

Sept. 20, 2021

Sept. 20, 2021

PACER
56

NOTICE of Voluntary Dismissal by Leonttayy Amir Pratt, Lamont Robinson (Feldman, Matthew) (Entered: 11/19/2021)

Nov. 19, 2021

Nov. 19, 2021

PACER

DOCKET ANNOTATION: Case CLOSED pursuant to stipulation 56 of dismissal. (mw)

Nov. 22, 2021

Nov. 22, 2021

PACER

Case Details

State / Territory: Pennsylvania

Case Type(s):

Jail Conditions

Speech and Religious Freedom

Special Collection(s):

Solitary confinement

Key Dates

Filing Date: Jan. 31, 2020

Closing Date: Nov. 22, 2021

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Two incarcerated men who were placed in solitary confinement for refusing to cut off their dreadlocks on religious grounds.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Pennsylvania Institutional Law Project

Public Interest Lawyer: Yes

Filed Pro Se: Yes

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Lebanon County, County

Defendant Type(s):

Corrections

Facility Type(s):

Government-run

Case Details

Causes of Action:

42 U.S.C. § 1983

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

Declaratory Judgment Act, 28 U.S.C. § 2201

Ex parte Young (federal or state officials)

Constitutional Clause(s):

Due Process

Due Process: Procedural Due Process

Due Process: Substantive Due Process

Free Exercise Clause

Equal Protection

Available Documents:

Trial Court Docket

Complaint (any)

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Damages

Source of Relief:

Settlement

Form of Settlement:

Private Settlement Agreement

Voluntary Dismissal

Amount Defendant Pays: $147,500

Issues

General/Misc.:

Classification / placement

Conditions of confinement

Discrimination Area:

Discipline

Discrimination Basis:

Race discrimination

Religion discrimination

Affected Race(s):

Black

Jails, Prisons, Detention Centers, and Other Institutions:

Administrative segregation

Confinement/isolation

Disciplinary segregation

Solitary confinement/Supermax (conditions or process)