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Plaintiff Jeffrey Coleman filed an action against the Virginia Department of Corrections (VDOC) alleging violations of his constitutional rights under the First Amendment, the Eighth Amendment, the Fourteenth Amendment, and RLUIPA. The Plaintiff claimed that these rights had been violated in over 12 policies, including the policy that limited his purchase of prayer oil to once a week, a grooming policy that prevented him from growing a beard, and a CD policy limiting inmates’ purchase of spoken religious word CDs to a single vendor. The District Court dismissed all claims against the Respondent except for claims related to the CD policy, which the District Court determined was not related to any legitimate penological interest.

Plaintiff Tabari Strong, a Muslim prisoner in Beeville, Texas, filed a lawsuit alleging that the prison's grooming policy requiring all inmates to be clean-shaven violated his statutory rights under RLUIPA. He also claimed that the policy violated his right to exercise his religion under the First Amendment, and that enforcement of the policy violated his right to equal protection under the Fourteenth Amendment. The plaintiff filed a motion for summary judgment, claiming that he is entitled to a declaratory judgment. The District Court refused to grant the plaintiff's request for injunctive relief as an "extraordinary remedy," but maintained that it would be contrary to justice not to grant the relief requested by the plaintiff to have a quarter-inch beard.

The Ohio Court of Appeals affirmed the trial court’s refusal to enforce an Islamic marriage contract, which called for a postponed dowry (mahr) owed by the husband to the wife upon death or divorce of $25,000. The Court found that the groom was coerced into signing the agreement, and thus it was not valid. The Court did not delve into the potential First Amendment Establishment Clause issues considered by the Franklin County Court of Common Pleas.

The applicants submitted that they were married in accordance with Islamic shari'a on 10 March 2009 before two witnesses. The second applicant's sibling had acted as her marriage guardian (wali nikah) and the dowry (mas kawin) had been IDR 30,000. At the time of the parties' marriage, the first applicant was a widower and the second applicant a divorcee. The parties were not blood relatives nor had they shared a wet-nurse. There were no other prohibitions to their marriage under Islam or current laws. The parties also had two children and no third party had ever sought to impugn the sanctity of their marriage. They had never, however, received a marriage certificate issued by the Office of Religious Affairs. The parties, therefore, requested that the court ratify their marriage for civil administration purposes.

The sole judge found that the parties' marriage met the requirements contained in art 14 of the Compilation of Islamic Laws because there had been a bridegroom, groom, marriage guardian, two witnesses, and the parties had exchanged vows (ijab kabul). The judge also cited expert Islamic jurisprudence (Ahli Fiqhi) found in Kitab Buhyatul Mustarsyidin, which stated that a marriage affirmed by witnesses present was indeed a marriage. Therefore, pursuant to art 1 of Law No. 1 of 1974 on Marriage, and art 3(e) of the Compilation of Islamic Laws, the judge acceded to the applicants' request.

The applicants submitted that they were married in accordance with Islamic shari'a on 14 February 1982 before two witnesses. The second applicant's father had acted as her marriage guardian (wali nikah) and the dowry (mas kawin) had been IDR 100,000. At the time of the parties' marriage, the first applicant was a bachelor (aged 34 years) and the second applicant a virgin (aged 27 years). The parties were not blood relatives nor had they shared a wet-nurse. There were no other prohibitions to their marriage under Islam or current laws. The parties also had two children and no third party had ever sought to impugn the sanctity of their marriage. They had never, however, received a marriage certificate issued by the Office of Religious Affairs. The parties, therefore, requested that the court ratify their marriage for civil administration purposes.

The sole judge found that the parties' marriage met the requirements contained in art 14 of the Compilation of Islamic Laws because there had been a bridegroom, groom, marriage guardian, two witnesses, and the parties had exchanged vows (ijab kabul). The judge also cited expert Islamic jurisprudence (Ahli Fiqhi) found in Kitab Buhyatul Mustarsyidin, which stated that a marriage affirmed by witnesses present was indeed a marriage. Therefore, pursuant to art 1 of Law No. 1 of 1974 on Marriage, and art 3(e) of the Compilation of Islamic Laws, the judge acceded to the applicants' request.

The applicants submitted that they were married in accordance with Islamic shari'a on 14 October 2014 before two witnesses. The second applicant's father had acted as her marriage guardian (wali nikah) and the dowry (mas kawin) had been IDR 360,000. At the time of the parties' marriage, the first applicant was a bachelor (aged 18 years) and the second applicant a virgin (aged 19 years). The parties were not blood relatives nor had they shared a wet-nurse. There were no other prohibitions to their marriage under Islam or current laws. The parties had no children but no third party had ever sought to impugn the sanctity of their marriage. They had never, however, received a marriage certificate issued by the Office of Religious Affairs. The parties, therefore, requested that the court ratify their marriage for civil administration purposes.

The sole judge found that the parties' marriage met the requirements contained in art 14 of the Compilation of Islamic Laws because there had been a bridegroom, groom, marriage guardian, two witnesses, and the parties had exchanged vows (ijab kabul). The judge also cited expert Islamic jurisprudence (Ahli Fiqhi) found in Kitab Buhyatul Mustarsyidin, which stated that a marriage affirmed by witnesses present was indeed a marriage. Therefore, pursuant to art 1 of Law No. 1 of 1974 on Marriage, and art 3(e) of the Compilation of Islamic Laws, the judge acceded to the applicants' request.

The applicants submitted that they were married in accordance with Islamic shari'a on 4 December 1999 before two witnesses. The second applicant's father had acted as her marriage guardian (wali nikah) and the dowry (mas kawin) had been IDR 100,000. At the time of the parties' marriage, the first applicant was a bachelor (aged 19 years) and the second applicant a virgin (aged 17 years). The parties were not blood relatives nor had they shared a wet-nurse. There were no other prohibitions to their marriage under Islam or current laws. The parties had three children and no third party had ever sought to impugn the sanctity of their marriage. They had never, however, received a marriage certificate issued by the Office of Religious Affairs. The parties, therefore, requested that the court ratify their marriage for civil administration purposes.

The sole judge found that the parties' marriage met the requirements contained in art 14 of the Compilation of Islamic Laws because there had been a bridegroom, groom, marriage guardian, two witnesses, and the parties had exchanged vows (ijab kabul). The judge also cited expert Islamic jurisprudence (Ahli Fiqhi) found in Kitab Buhyatul Mustarsyidin, which stated that a marriage affirmed by witnesses present was indeed a marriage. Therefore, pursuant to art 1 of Law No. 1 of 1974 on Marriage, and art 3(e) of the Compilation of Islamic Laws, the judge acceded to the applicants' request.

The applicants submitted that they were married in accordance with Islamic shari'a on 3 April 2001 before two witnesses. The second applicant's father had acted as her marriage guardian (wali nikah) and the dowry (mas kawin) had been IDR 10,000. At the time of the parties' marriage, the first applicant was a bachelor (aged 29 years) and the second applicant a virgin (aged 28 years). The parties were not blood relatives nor had they shared a wet-nurse. There were no other prohibitions to their marriage under Islam or current laws. The parties had two children and no third party had ever sought to impugn the sanctity of their marriage. They had never, however, received a marriage certificate issued by the Office of Religious Affairs. The parties, therefore, requested that the court ratify their marriage for civil administration purposes.

The sole judge found that the parties' marriage met the requirements contained in arts 14 of the Compilation of Islamic Laws because there had been a bridegroom, groom, marriage guardian, two witnesses, and the parties had exchanged vows (ijab kabul). The judge also cited expert Islamic jurisprudence (Ahli Fiqhi) found in Kitab Buhyatul Mustarsyidin, which stated that a marriage affirmed by witnesses present was indeed a marriage. Therefore, pursuant to art 1 of Law No. 1 of 1974 on Marriage, and art 3(e) of the Compilation of Islamic Laws, the judge acceded to the applicants' request.

The applicants submitted that they were married in accordance with Islamic shari'a in 2004 before two witnesses. The second applicant's parents had acted as her marriage guardians (wali nikah) and the dowry (mas kawin) had been IDR 50,000. At the time of the parties' marriage, the first applicant was a bachelor (aged 28 years) and the second applicant a virgin (aged 23 years). The parties were not blood relatives nor had they shared a wet-nurse. There were no other prohibitions to their marriage under Islam or current laws. The parties had two children and no third party had ever sought to impugn the sanctity of their marriage. They had never, however, received a marriage certificate issued by the Office of Religious Affairs. The parties, therefore, requested that the court ratify their marriage for civil administration purposes.

The sole judge found that the parties' marriage met the requirements contained in arts 14 of the Compilation of Islamic Laws because there had been a bridegroom, groom, marriage guardian, two witnesses, and the parties had exchanged vows (ijab kabul). The judge also cited expert Islamic jurisprudence (Ahli Fiqhi) found in Kitab Buhyatul Mustarsyidin, which stated that a marriage affirmed by witnesses present was indeed a marriage. Therefore, pursuant to art 1 of Law No. 1 of 1974 on Marriage, and art 3(e) of the Compilation of Islamic Laws, the judge acceded to the applicants' request.

The parties were married on 8 January 2006 and had three children. Before moving to their own home, they had first lived with the respondent's parents for three months, and then the applicant's parents for six months. The applicant submitted that, by July 2006, the parties' marriage had become quarrelsome because:

1. the parties once quarrelled because the applicant left the matrimonial home to attend a wedding because the bride and groom had hired his soundsystem;
2. in 2007, the parties quarrelled because the applicant had left for Kupang to be with his parents who were farewelling the applicant's sibling who was returning home to Java - the respondent objected to the applicant doing so, even becoming angry with the applicant and his parents;
3. in 2008, the parties quarrelled again when the applicant opened an internet cafe in Atambua, which resulted in the applicant often not returning home until the evening, the respondent becoming angry with the applicant, directing profanities at the applicant and even threatening to stab him with a knife;
4. at the end of 2008, the respondent would often conduct herself in an impolite manner, failing to show any appreciation for the applicant as her husband, even being impolite towards the applicant's parents; and
5. in October 2012, when the applicant wanted to leave for Betun to mourn the loss of a friend, the applicant had objected.

As a result, the parties had been separated since October 2012, the applicant living in Atambua, while the respondent had been living in Halilulik. The applicant submitted that it was no longer feasible for the parties to create a peaceful, hopeful and loving (sakinah, mawaddah dan rahmah) domestic life and, therefore, sought a revocable divorce (talak satu raj'i).

The respondent rejected all of the applicant's submissions, submitting that the marriage could be salvaged, and that the court should dismiss the applicant's request for a divorce.

The court acknowledged that the parties' evidence conflicted. It also noted, however, that the applicant had already failed, on two occasions, to produce two witnesses to attest to his submissions. Therefore, citing Kitab Al Muhadzdzab Juz II, page 320, the applicant's failure to provide sufficient evidence meant his request had to be dismissed.