Trapp v. Roden
Annotate this CaseIn 1995, Randall Trapp and four other inmates, who were adherents of Native American religious practices, filed a complaint asserting that the Department of Correction (DOC) had violated their rights to exercise their religion. In 2003, the parties entered into a settlement agreement requiring the DOC to construct a purification lodge at the Souza-Baranowski Correctional Center (SBCC). Within six months of building the SBCC lodge, the DOC halted all ceremonies, citing health concerns that resulted from smoke filtering into the main building from wood fires at the lodge. In 2010, Trapp and Robert Ferreira filed an amended complaint against the Commissioner of Correction and two DOC employees at the Massachusetts Correctional Institution at Norfolk, alleging that the lodge’s closure violated the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), article 2 of the Massachusetts Declaration of Rights, and the 2003 settlement agreement. A superior court judge entered a declaratory judgment in favor of Plaintiffs on all three claims. The Supreme Judicial Court affirmed, holding that the closure of the SBCC lodge violated RLUIPA and the settlement agreement.
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