Pennsylvania County Pays $147,500 to Jail Detainees Held in Solitary for Refusing To Cut off Dreadlocks
by Matt Clarke
On January 6, 2022, the Pennsylvania Institutional Law Project (PILP) announced a settlement had been reached in a lawsuit filed for a trio of its clients, who were thrown in solitary confinement while incarcerated at the Lebanon County Correctional Facility (LCCF) after they refused to cut off their dreadlocks. Under the settlement’s terms, the county agreed to change its hair policy and pay $147,500 to the three men, Leonttayy Pratt, Eric S. McGill, Jr., and Lamont Chambers.
All three are practicing Rastafarians, for whom dreadlocks are “an important part of the Rastafarian way of life,” according to complaints they later filed. In early 2019, they were pretrial detainees at LCCF, which had a policy prohibiting dreadlocks. The three were ordered to cut theirs off and, when they refused, were punished with placement in the jail’s segregated housing unit (SHU).
There McGill languished for fifteen months. Pratt stayed for five months and Robinson for three months. SHU conditions were onerous, with prisoners locked in their cells 24 hours a day except for one hour a day five times a week for “recreation”—which also included using the phone, and always between 12:00 midnight and 2:00 a.m. They were subjected to near-continuous illumination and limited to five-minute showers and one 30-minute visit each week, compared to thrice-weekly visits of up to 150 minutes each for general population prisoners. Unlike general population prisoners, those in SHU were prohibited from receiving books or photographs by mail and were permitted to purchase only hygiene items from the commissary.
With the aid of PILP attorneys Alexandra Morgan-Kurtz and Matthew A. Feldman, McGill filed suit in February 2020 and the other two men the following May, all in federal court for the Middle District of Pennsylvania, accusing jail officials of violating the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. § 2000cc-1, also lodging claims under 42 U.S.C. § 1983 for alleged violations of their First and Eighth Amendment rights.
After the lawsuits were filed, on April 23, 2020, the jail changed its policy to allow a religious exemption to the prohibition against dreadlocks, and the men were released from solitary confinement. The County then filed motions to dismiss both suits.
Quoting Bell v. Wolfish, 441 U.S. 520 (1979), the Court said that “under the Due Process Clause, a [pretrial] detainee may not be punished prior to an adjudication of guilt in accordance with due process of law.” Since throwing Plaintiffs in SHU was clearly punitive, Defendants had the burden to prove it was “rationally related to a legitimate non-punitive government purpose” and not “excessive in light of that purpose,” the Court said. When they couldn’t, the Court largely denied Defendants’ motions to dismiss in early 2021. See McGill v. Clements, 2021 U.S. Dist. LEXIS 12416 (M.D. Pa.); and Pratt v. Ott, 2021 U.S. Dist. LEXIS 62397 (M.D. Pa.).
After the latter decision was handed down on March 31, 2021, the parties proceeded to reach their settlement agreement, under which LCCF policy was amended to state: “Inmates are not restricted with regard to the length or style of their hair, so long as hair is maintained in a manner that does not pose a concern to the health, safety, and security of the facility.” See: McGill v. Clements, USDC (M.D. Pa.), Case No. 3:19-cv-01712; and Pratt v. Ott, USDC (M.D. Pa.), Case No. 1:20-cv-00171.
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Related legal cases
McGill v. Clements
| Year | 2021 |
|---|---|
| Cite | 2021 U.S. Dist. LEXIS 12416 (M.D. Pa.) |
| Level | District Court |
| Conclusion | Bench Verdict |
Pratt v. Ott
| Year | 2021 |
|---|---|
| Cite | 2021 U.S. Dist. LEXIS 62397 (M.D. Pa.) |
| Level | District Court |
| Conclusion | Bench Verdict |
McGill v. Clements
| Year | 2021 |
|---|---|
| Cite | USDC (M.D. Pa.), Case No. 3:19-cv-01712 |
| Level | District Court |
| Conclusion | Bench Verdict |
Pratt v. Ott
| Year | 2021 |
|---|---|
| Cite | USDC (M.D. Pa.), Case No. 1:20-cv-00171 |
| Level | District Court |
| Conclusion | Bench Verdict |