Filed Date: April 4, 1973
Clearinghouse coding complete
On April 4, 1973, a Native American inmate of the Iowa State Penitentiary, in Fort Madison, Iowa, filed a lawsuit pursuant to 42 U.S.C. § 1983 against the Penitentiary's warden and other Iowa State prison authorities in the United States District Court for the Southern District of Iowa. The plaintiff, represented by the Native American Rights Fund, alleged that prison authorities had violated the First and Fourteenth Amendments by limiting inmates' hair length, regardless of religious and ethnic heritage.
On November 20, 1974, the United States District Court for the Southern District of Iowa (Chief Judge William C. Hanson) held that an inmate should be allowed to grow long hair if there was a good faith link between religious expression and hair length. Teterud v. Gillman, 385 F. Supp. 153 (S.D. Iowa 1974). The court was not persuaded that the State's interests in limiting hair length, such as sanitation and potential safety problems did not outweigh the inmate's interest to freely express his Native American religion. The court enjoined enforcement of the Iowa State Penitentiary's hair regulation against the plaintiff. The court, however, refused to certify the class.
On September 4, 1975, the United States Court of Appeals for the Eighth Circuit (Judge Gerald W. Heaney) affirmed the District Court's order, recognizing that limiting a Native American's hair length was an unconstitutional infringement on the freedom of religion. Teterud v. Burns, 522 F.2d 357 (8th Cir. 1975). The court held that the plaintiff satisfied the burden of proof by showing that his hair length was connected to sincere religious beliefs and refused to require that hair length be an orthodox form of religious expression.
We do not have the docket, pleadings, or record of any subsequent proceedings in this case.
Summary Authors
Elizabeth Chilcoat (6/1/2006)
Bartels, Robert D. (Iowa)
Haber, Roy S. (Oregon)
Barnett, Walter W. (District of Columbia)
Dimsey, Dennis J. (District of Columbia)
Donielson, Allen L. (District of Columbia)
Last updated March 25, 2024, 3:06 a.m.
Docket sheet not available via the Clearinghouse.State / Territory: Iowa
Case Type(s):
Key Dates
Filing Date: April 4, 1973
Case Ongoing: No
Plaintiffs
Plaintiff Description:
American Indian inmate of Iowa State Penitentiary challenging enforcement of prison's hair regulation against plaintiff and other Indian inmates
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: Unknown
Class Action Sought: Yes
Class Action Outcome: Denied
Defendants
Iowa State Penitentiary, State
Facility Type(s):
Case Details
Causes of Action:
Constitutional Clause(s):
Available Documents:
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Order Duration: 1974 - 0
Issues
General/Misc.:
Discrimination Basis: