HAMMOND v. HARRY

CourtDistrict Court, E.D. Pennsylvania
DecidedJanuary 31, 2025
Docket2:24-cv-05526
StatusUnknown

This text of HAMMOND v. HARRY (HAMMOND v. HARRY) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HAMMOND v. HARRY, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

KHALIL HAMMOND, : Plaintiff, : : v. : Civ. No. 24-CV-5526 : DR. LAUREL R. HARRY, et al., : Defendants. :

MEMORANDUM GOLDBERG, J. January 31, 2025

Khalil Hammond, a prisoner in custody at SCI Phoenix, filed this action naming as Defendants the current and former Secretaries of the Pennsylvania Department of Corrections (“DOC”),1 other DOC employees, Governor Joshua Shapiro, and the Pennsylvania General Assembly. All Defendants are named in their individual and official capacities. Hammond asserts that his constitutional rights were violated in two distinct ways, first by a DOC policy concerning the celebration of Muslim religious holidays, which also is the basis of a statutory claim under the Religious Land Use and Institutional Persons Act (“RLUIPA”), and second because the DOC earns interest on funds he holds in his institutional account without crediting that interest to him. Hammond also seeks leave to proceed in forma pauperis. For the following reasons, the Court will grant Hammond leave to proceed in forma pauperis and dismiss the claims in part.

1 Hammond identifies Dr. Laurel R. Harry, the current DOC Secretary, as well as George Little who previously held that post. While Hammond identifies John Wetzel in the body of his Complaint as another former Secretary, he did not list him in the caption of the Complaint. He also makes no factual allegations about how Wetzel was involved in the actions he describes. Accordingly, the Court does not understand Hammond to be asserting any claims against Wetzel. I. FACTUAL ALLEGATIONS2 Hammond alleges that he is a practicing Muslim since birth and closely follows the precepts of his faith. (Compl. at 3-4.) Two of the most important celebrations of his faith are Eid al-Fitr and Eid al-Adha, both of which happen after a period of fast and end with prayer and a

ceremonial meal involving certain foods. (Id. at 4.) He alleges that as of January 1, 2023, as authorized by Defendant Little, the DOC changed a policy about the allowance and facilitation of the “feast” meal at the end of the fast.3 (Id. at 5.) Hammond claims that Little distributed a memo on February 24, 2022 explaining that the DOC was “transitioning from the formerly allowed feast to ‘fellowship meals.’” (Id.; see also id. at 23 (Little Memo dated 2/24/22)). Little wrote to “all inmates” to advise them that: Beginning January 1, 2023, faith groups accommodated with Ceremonial Meals will instead be accommodated with up to two (2) Fellowship Meals a year. Fellowship Meals permit inmates of those faith groups to provide input on the mainline “best meal” to be served at two holy day observances per year; however, optional menu items will no longer be available. Additionally, members of each faith group will be able to eat together and afterwards engage in thirty (30) minutes of fellowship, provided communal gatherings are permitted at that time. (Id. at 23.) Hammond alleges that “a fellowship meal in the PA.D.O.C. is nothing more then [sic] a meal from the regularly scheduled daily menu that inmates of a faith group are allowed to eat together.” (Id. at 5.) He asserts that the Little Memo served no reasonable or legitimate penological purpose and fellowship meals “don’t conform to Islamic standards of a traditional feast as was followed in the PA.D.O.C. for over half a century.” (Id.) Hammond asserts that the

2 Unless otherwise stated, the factual allegations set forth in this Memorandum are taken from Hammond’s Complaint. (ECF No. 1). The Court adopts the sequential pagination assigned to the Complaint by the CM/ECF docketing system. When quoting the Complaint, punctuation and capitalization errors are cleaned up.

3 The Court notes that the Eid al-Fitr for 2023 occurred on April 20-21, 2023, and for 2024 it took place on April 9-10, 2024. The Eid al-Adha for 2023 occurred on June 27-28, 2023, and for 2024 it took place on June 16-17, 2024. implementation of fellowship meals was “in retaliation for inmates (of prior unrecognized faith groups) asserting their rights to equal treatment in regards to the ceremonial mandates of their religions for feast.” (Id.) Hammond alleges that Pennsylvania’s prison system targeted Muslims in the DOC by

stripping their right to religious feasts. (See id. at 6.) In contrast, he asserts, Jewish prisoners “never lost access to specially ordered Kosher products daily for their fast and for their feasts.” (Id.) Inmates housed in the restricted housing unit did not have access even to fellowship meals due to that status.4 (Id.) He alleges that Defendants Little, Harry, and Ulli Klem, the DOC employee responsible for religious activities, interfered in the free exercise of religion by interfering in his participation in the two holidays’ meals and congregate prayer. (Id. at 6-7.) On November 15, 2023, Defendant Harry issued an updated memo concerning religious meals, adjusting the procedures to be followed but not reinstating the prior “authorized feasts.”5 (Id. at 7; see also id. at 25 (Harry Memo dated 11/15/23)). The Harry Memo established a policy of permitting up to two “Religious Meals (formerly called Fellowship Meals)” per year; set forth

procedures for groups to request and schedule their Religious Meals; stipulated that no state funds or Inmate General Welfare Fund (“IGWF”) monies could be used to subsidize the purchase of specialty food items; provided that general population inmates with sufficient funds could place a group order for one identical inmate-purchased shelf-stable food item from an approved vendor to supplement each Religious Meal; and established rules for conducting Religious Meals that

4 While Hammond alludes to himself as an inmate who has been housed in restricted housing, he does not allege specifically that he was in restricted housing when one of the Muslim holidays occurred and thus personally was unable to attend one of the fellowship meals.

5 As the Harry Memo was dated November 15, 2023, it would have superseded the Little Memo and applied to the Eid al-Fitr occurring on April 9-10, 2024 and the Eid al-Adha occurring on June 16-17, 2024. included time to engage in group religious practice after the meal was consumed. (Id. at 25-28.) Hammond contends that the new directives also do not conform to the specifications of a halal feast, infringe upon the free exercise rights of inmates like himself, have no penological purpose, and were intended “to frustrate and deter those wishing to participate in ‘feasts’ from doing so.”

(Id. at 7-8.) He cites to provisions in the policy that allegedly require that, in order for an inmate to participate in a religious meal, an inmate must have participated in six-months of religious services prior to the meal and be free of misconducts for a period of six-months.6 (Id. at 8.) Hammond alleges that “DOC actors” have the ability to decide who can and who cannot participate in Religious Meals since an inmate must be deemed to be “in good standing” to participate.7 (Id.) Hammond contends that one institution, SCI Albion, must provide religious feasts due to a preliminary injunction issued by a federal court, but that Defendants Harry and Klemm failed to ensure that inmates in other DOC facilities had the same access.8 (Id. at 8-9.) He alleges the Defendants have also violated RLUIPA. (Id. at 9.)

6 I note that there are no such specific “six-month” provisions stated in the Harry Memo. It states only that inmates may obtain a Religious Meal if “they identify, in the Unit Management System, with the religion being accommodated with a Religious Meal – or who have a religious accommodation stating they can attend the religious activities associated with an accommodated religion.” (Compl. at 26 (Harry Memo) at ¶ 13).)

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HAMMOND v. HARRY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hammond-v-harry-paed-2025.