Michael Malik Allah, Minister Khalil Wali Muhammad Michael Malik Allah v. Humza Al-Hafeez William W. Ennis, Rev. United States of America, Intervenor
Docket: 15-2132
Court: Court of Appeals for the Third Circuit; September 6, 2000; Federal Appellate Court
Michael Malik Allah appeals the dismissal of his claims regarding the infringement of his First Amendment right to free exercise of religion, as ruled by the District Court. His pro se complaint, filed in 1996, named Humza Al-Hafeez, a chaplain, and William W. Ennis, an appointed outside minister for the Nation of Islam at S.C.I. Frackville, as defendants. Allah contends that Al-Hafeez's teachings contradict those of Elijah Muhammad, thus violating his rights and those of other Nation of Islam followers. He seeks injunctive relief and monetary damages.
In April 1997, Allah amended his complaint to include 26 additional defendants, alleging harassment and retaliation for his lawsuit and religious practices; however, these defendants were never served. Following his transfer to S.C.I. Greene in July 1997, Ennis and Al-Hafeez moved for judgment on the pleadings in April 1998, arguing that Allah's request for injunctive relief was moot due to his transfer, and that his damage claims were barred by the Prison Litigation Reform Act (PLRA), specifically 42 U.S.C. § 1997e(e). The District Court granted their motion and dismissed the case without addressing the unserved defendants or the retaliation claims. Allah subsequently filed a timely appeal.
Counsel was appointed to represent Allah in his appeal, which was consolidated with another appeal, Allah v. Seiverling, No. 97-3627. The appeals involve distinct legal issues and are addressed separately. The court has jurisdiction under 28 U.S.C. § 1291 and reviews the District Court's dismissal of Allah's complaint under Fed. R. Civ. P. 12(c) with plenary review, accepting all allegations as true and drawing reasonable inferences in favor of Allah. The court can affirm the District Court's judgment only if no relief can be granted under any potential facts.
Section 1997e(e) restricts federal civil actions by prisoners for mental or emotional injuries without a prior showing of physical injury. Allah acknowledges that his claims for injunctive relief have been mooted due to his transfer, leaving only his claims for damages for consideration. He argues these damages arise from violations of his First Amendment rights. The language of § 1997e(e) applies uniformly to all federal civil actions.
Compensatory damages under § 1983 are based on general tort-law principles, allowing recovery for constitutional rights violations that lead to compensable injuries. The Supreme Court has clarified that compensatory damages may include out-of-pocket losses, reputational harm, and emotional distress. However, substantial damages can only be awarded for actual injuries suffered from constitutional violations, as demonstrated in previous rulings where awards were overturned due to improper jury instructions or lack of evidence for actual harm. The abstract value of a constitutional right cannot justify damages under § 1983.
Allah's claims for compensatory damages due to alleged violations of his First Amendment rights are barred by 42 U.S.C. § 1997e(e), which requires that a prisoner must show physical injury to recover for mental or emotional injury while in custody. Allah's complaint does not allege any physical injury, thus rendering his claims for compensatory damages appropriate for dismissal. Although he cites footnote 14 of the Stachura opinion to argue for the possibility of measuring damages without evidence of mental or emotional injury, that footnote pertains specifically to voting rights cases, and the broader context of Stachura does not support his position as it emphasizes the need for a showing of actual harm.
While § 1997e(e) bars Allah's claims for compensatory damages, it does not prevent him from seeking nominal damages, which can be awarded for violations of constitutional rights in the absence of actual injury, as recognized in Carey and Stachura. Nominal damages serve to vindicate rights even when no provable injury has occurred, and federal courts have consistently awarded them for First Amendment violations. Although Allah does not explicitly request nominal damages in his complaint, the court interprets his pro se complaint liberally, aligning with the precedent that allows for such claims even without explicit mention. Given the nature of his allegations, the court concludes that Allah's complaint effectively requests nominal damages.
Punitive damages can be awarded based on a constitutional violation if properly demonstrated, as supported by case law including Alexander v. Riga and Coleman v. Kaye. Under 42 U.S.C. § 1983, such damages are justified when a defendant's actions show malicious intent or indifference to federally protected rights, with the intent to punish and deter future misconduct. Claims for punitive damages related to a First Amendment violation are not considered claims for mental or emotional injury and thus are not restricted by § 1997e(e). The statute specifies that federal civil actions cannot be brought for mental or emotional injuries without prior proof of physical injury. Therefore, claims for nominal or punitive damages that aim to vindicate constitutional rights are permissible under this statute.
The document references cases from other circuits, notably Canell v. Lightner and Rowe v. Shake, affirming that prisoners can assert First Amendment claims without needing to demonstrate physical injury. The ruling in Davis v. District of Columbia is distinguished, as it involved claims solely based on emotional distress without mention of nominal damages, leading to its exclusion under § 1997e(e). The court emphasizes that the intention of § 1997e(e) is to bar claims for emotional injuries while allowing for claims that vindicate constitutional rights or punish violations of those rights.
Allah's claims for compensatory damages are barred by Section 1997e(e), but his claims for nominal damages are permissible. Additionally, if Allah's punitive damages claims are based on a violation of his free exercise of religion rather than emotional or mental distress, those claims are also allowed. The court will partially affirm and partially reverse the District Court's judgment favoring defendants Al-Hafeez and Ennis, remanding for further proceedings. The District Court must also address the status of 26 defendants who were authorized for joinder but overlooked in the dismissal order. The complaint, signed by 21 members of the Nation of Islam, includes affidavits regarding Al-Hafeez's teachings. The District Court previously dismissed Allah's claims against Al-Hafeez and Ennis due to them being doctrinal disputes within Islam, a rationale not presented by the defendants, which the appellate court found erroneous. The court acknowledges the role of counsel representing Allah pro bono and notes that it does not address the constitutionality of Section 1997e(e) as it is not necessary given their current findings. Other courts have upheld the section's limitations on damages against constitutional challenges. The court refrains from commenting on the merits of Allah's claims.
