LITTLE ROCK -- The ACLU of Arkansas, alongside national civil rights attorneys at Morrison Foerster, filed a federal lawsuit today on behalf of Gregory Holt, also known as Abdul Maalik Muhammad, a devout Muslim and renowned jailhouse litigator. Muhammad was recently transferred to a federal prison in West Virginia in what he alleges was an act of unconstitutional retaliation by Arkansas prison officials.
Muhammad has spent over a decade using the legal system to defend not only his own civil rights, but the rights of fellow incarcerated people across Arkansas. His landmark Supreme Court victory in Holt v. Hobbs (2015) secured religious liberty protections for people in prison nationwide. Yet now, despite years of good behavior, Muhammad has been abruptly transferred out of Arkansas, stripped of access to his legal papers, and placed in solitary confinement at one of the most dangerous federal prisons in the country — far from his counsel, his court cases, and the community he fought to serve.
The new lawsuit alleges that Arkansas Division of Correction Director Dexter Payne initiated Muhammad’s transfer in direct response to ongoing, active litigation and after confidential settlement talks failed. The complaint asserts that the transfer was a deliberate attempt to disrupt Muhammad’s legal advocacy on behalf of himself and other incarcerated people.
“This transfer wasn’t about safety or security — it was about punishment,” said John C. Williams, Legal Director of the ACLU of Arkansas. “Mr. Muhammad has exercised his First Amendment right to petition the courts and hold prison officials accountable. For that, they sent him over 1,000 miles away, denied him medical care, and cut off his communication with counsel. That’s unconstitutional retaliation.”
Since his transfer to USP Hazelton — dubbed “Misery Mountain” for its deadly conditions — Muhammad has been denied access to basic hygiene, religious services, and contact with his lawyers. He has lost access to ongoing casework and legal documents that support his work both as a plaintiff and as a resource for fellow prisoners seeking justice.
“The State of Arkansas may resent being held accountable by a skilled litigator behind bars,” said Holly Dickson, Executive Director of the ACLU of Arkansas, “but it does not have the right to retaliate against someone for exercising their constitutional rights. Mr. Muhammad’s case is about more than one man — it’s about preserving access to justice and defending the right to speak truth to power, no matter where you live or where you’re confined.”
The lawsuit seeks a court order requiring Arkansas to return Muhammad to the custody of the Arkansas Division of Correction and restore his ability to participate in his ongoing litigation. It also requests a declaration that Muhammad’s transfer violated his First and Fourteenth Amendment rights to seek legal redress and be free from retaliation.
Unconstitutional actions by prison officials such as this cannot be allowed to stand. They threaten the foundational promise of equal justice under law, especially for those with the fewest resources and greatest barriers to vindicating their rights.
“Mr. Muhammad is committed to pursuing justice. For him to continue promoting civil rights in Arkansas, the ADC needs to transfer him back home,” said Carolyn Homer, of Counsel at Morrison Foerster.
The ACLU of Arkansas and Morrison Foerster are committed to holding the Division of Correction accountable and defending the rights of all Arkansans.
Read the preliminary injunction brief here.