APPENDIX

Table of cases

US Supreme Court cases

Bradwell v. Illinois, 83 US 130 (1873)

Federal Court cases

Shikoh v. Shikoh, 257 E2d 306 (2d Cir. 1958)

State Court cases

Adra v.

Aghili v. Saadatnejadi, 958 S.W.2d 784 (Ct. App. Tenn. 1997) Ahmed v. Ahmed, 689 N.Y.S.2d 357 (Sup. Ct. NY 1999)

Akileh υ. Elchahal, 666 S0.2d 246 (Fla Ct. App. 1996)

Ali v. AU, 652 A.2d 253 (NJ Sup. Ct. 1994)

Arain v. Arain, 20g A.D.2d 406 (1994)

Aziz v. Aziz, 488 N.Y.S.2d 123 (NY Sup. Ct. 1985)

Dajani v. Dajani, 204 Cal. App. 3d 1387 (1988)

Farah v. Farah, 429 S.E.2d 626 (Ct. App. VA 1993) Habibi-Fahnrich v. Fahnrich, WL 507388 (NY Sup. 1995) Hosain v. Malik, 671 A.2d 988 (Ct. App. Md. 1996) In Re Marriage of Murga, 103 Cal. App. 3d 498 (1980) Jabri v. Jabri, 598 N.Y.S. 2d 535, 537 (1993)

Kapigian v. Der Minassian, 99 N.E. 264 (Mass. Sup. Ct. 1912) Maklad v. Maklad, WL 51662 (Conn. Super. Jan. 3, 2001) Malakυ. Malak, 182 Cal. App. 3d 1018 (1986)

AIehtar v. Mehtar, 1997 Conn. Super. LEXIS 2400

NY υ. Benu, 385 N.YS.2d (Crim. Ct. NY 1976)

Odatalla v. Odatalla, 810 Λ.2d 93 (NJ Super. 2002)

Ohio v. Awkal, 667 N.E.2d 960 (Sup. Ct. Ohio 1996)

Seth v. Seth, 694 S.W.2d 459 (Ct. App. TX 1985)

Shaban υ. Shaban, 88 Cal. App. 4tl1 398 (2001)

Shike v. Shike, Tex. App. LEXIS 2733 (April 27, 2000) Shikoh v. Shikoh, 257 F.2d 306 (2d Cir. 1958)

Tazziz v. Tazziz, 533 N.E.2d 202 (Mass. App. Ct. 1988) Vryonis v. Vryonis, 202 Cal. App. 3d 712 (CA Ct. App. ιg88) Jurnmo v. Jummo, 574 A.2d 1130 (Pa. ιggo)

Notes to Part III

Our sincere thanks to Steve Vieux and Abed Awad for their helpful research assistance, and to all those who shared their experiences and expertise in our interviews with them (see attached interview list).

1. Anglo-American family law itself has religious Christian origins, as acknowledged in Bradwell v.

2. The research material for this study is comprised of: interviews with professionals who serve the US Muslim community, legal research of current United States federal and state case law, review of general literature (books, magazines, newspapers) addressing issues concerning Muslims in the United States, internet searches of Muslim-related sites, and the professional experiences of the authors. As the research time was constrained due to publication deadlines, the report is itself quite limited, and makes no claim to be exhaustive of all issues, resources, scholars and other elements potentially relevant to this topic. For surveys conducted by other sources, see Haddad and Lummis (1987). Haddad and Lummis studied eight mosques located in the Midwest, upstate New York and the East Coast over a period of two years. They focused on personal backgrounds and religious attitudes of the seventy to eighty participants in the study. Haddad and Lummis Stnveyed 346 Muslims, 64 per cent of whom were immigrants, and 16 per cent were children of immigrant parents. Thirty-four per cent of their sample were Lebanese American, 28 per cent were Pakistanis, with individuals from other Arab nations comprising the remainder of the sample. Another useful and more recent study is The Mosque in America: A National Portrait (Bagby et al. 2001), sponsored by a number of Muslim organizations and part of a larger study of American congregations coordinated by Hartford Seminary's Hartford Institute for Religious Res­earch. The project included a random sampling from 1,209 mosques across the United States, based on responses from 416 mosque leaders. The new suιvey showed African Americans were the dominant ethnic group in 27 per cent of mosques, South Asians in 28 per cent and Arabs in 15 per cent, with the remaining mosques described as ‘pluralistic’ (ibid., p.

3. See American Muslim Council (1992). The number of Muslims in the USA con­tinues to be an unsettled issue. Haddad and Lummis (1987: 3) noted that these might be between 2 and 3 million. The Mosque in America project findings reflect 2 million Muslims who attend or participate in mosques to a varying degree, with an overall estimate of 6­7 million Muslims present in the USA (Bagby et al. 2001: 3). One of the supreme challenges for counting the number of Muslims in the USA is the fact that there remains a large, as identified by Haddad and Lummis (1987: 9), ‘unmosqued’ proportion of the population who not have a direct and regular affiliation with a mosque.

4. See Quraishi (2001); Al-'Alwani (1993: chapter on Ikhtilaf)-, Abou el-Fadl (1997: 18) notes the belief that ‘a major contributing factor to the diversity of Islamic theological and legal schools is the acceptance and reverence given to the idea of Ikhtilqf (disagreement)’.

5. See Sciolino (1996) on different ‘versions’ of Islamic law regarding marriage.

6. See Haddad and Lummis (1987) for a discussion on imams in the United States.

7. Azam’s ‘The Muslim Marriage Guide’, at (reviewing Maqsood 1998).

8. See for example the articles by Raga El Nimr and Najla Hamadeh in Yamani (I99θ)∙

9. See The Muslim Women’s League is based in Los Angeles, California. Other Muslim women’s organizations interested in similar work in­clude the DC-based Georgetown Muslim Women’s Study Project (organized to review the UN Platform for Action prior to the 1995 Beijing Fourth UN World Conference on Women), and the North American Council for Muslim Women (NACMW), based in Virginia, which was launched in 1992 with a large national conference.

10.See

it. See

12.The fora email is sisters@post.queensu.ca

13.See

14.Similarly, the Canadian Society of Muslims includes on its website many sources of Islamic jurisprudence, as well as articles on ‘Family Matters' addressing such topics as birth control and abortion, adoption, custody and guardianship, polygamy, arranged marriage, and women’s rights in an ‘Islamic prenuptial agreement’.

15.See

16.See al-Khateeb (1996: 15). Similarly, another source says: ‘The Islamic marriage contract is meant to solidify bond and specify stipulations that are important to both parties. The contract is intended to safeguard present and future legal rights of both the husband and wife, should encourage marital harmony, and should keep the family within the boundaries of the Qur'an and Sunna for the pleasure of Allah.’ See ‘Cont... The Marriage Contract’ at

17.A Conference on the Islamic Marriage Contract’, Haivard Law School Islamic Legal Studies Program, 29-31 January 1999.

18.For popular dissemination of this information, see al-Khateeb (1996) for a list of sample stipulations and Mills for similar suggestions. For a more detailed, academic discussion of contract stipulations, including specific examples, see Welchman (2000: 35), Shaham (1995: 464) and Abou el-Fadl (1999).

19.Compare Mills who leaves out Islamic jurisprudential differences in a list of sug­gested stipulations in the marriage contract with Abou el-Fadl (1999) who explains general Hanbali allowances of contractual stipulations, compared with other schools’ reluctance on the same, and their use of legal devices created to accomplish similar goals.

20.See

21.See al-Hibri (1997: 28) who notes differing validity depending on school of thought; Wclchman (2000: 167); and Carroll (1982: 277).

22.See the article, ‘An Islamic Perspective on Divorce’, at Similarly, the Muslim Women’s League points out that classical custody laws (deciding custody based on abstract rules of the age and gender of the child) are among those that must ‘adapt to dynamic circumstances’, commenting that there is ‘no Qur^,anic text to substantiate the arbitrary choosing of age as a determinant for custody’. The League urges similar flexibility in determining alimony awards as well.

23. See Akileh v. Elchahal (1996), a case involving two separate marriage contracts — an Islamic sadaq and a civil ceremony the following day incorporating the sadaq document specifying the wife’s dower; Ahmed v.

24. See Tazziz v. Tazziz (1988), a marriage ceremony in the United States, in accordance with Islamic law; NYv. Benu (1976), a marriage performed by a local New York City imam not authorized in a city clerk’s office to perform marriages; the Awad interview (2000), in which the lawyer describes mosques in New York and New Jersey performing weddings with no state licensing; and McCloud (2000: 140) who urges Muslim women in the USA to get civil documents of both marriage and divorce. Some US Muslims, less concerned with Islamic law per se, may have only the civil ceremony, forgoing the Muslim one entirely, but these cases do not fall within the subject of this study.

25. See Farah v. Farah (1993) (deferred mahr of $20,000); Akileh v. Elchahal (1996) (im­mediate sadaq of $1 and deferred $50,000; noting that when he proposed, the husband ‘recognized that wife had the right to a sadaq j; NY v. Benu (1976) (sewing machine as dower).

26. See also marriage contracts on file with author (Quraishi). Islamic history verifies the use of non-monetary mahr. For example, a hadith from the Prophet explicidy validates the teaching of sections of the Qur'an (Doi 1984: 163) and the shahada (declaration of Islamic faith) of the groom as dower; see Ibn Sa'd (1997: 279) describing Umm Sulaim’s marriage to Abu Talha, and stating that ‘her dower was the Islam of Abu Talha^,.

27. Kadri comments (interview, 2000) on her experience with clients whose only interest in attempting to enforce a mahr provision is in unfriendly divorce proceedings, with the demand for a high mahr being used as an opportunity to punish the husband.

28. See listserve email discussions on ‘Sistersnet’ (sisters@post.queensu.ca) in 1996-98 (notes on file with author Quraishi).

29. Ali (1996) comments that when divorce litigation is bitterly contested by a Muslim husband, it is often not because he does not want a divorce, but rather because he does not want to pay the mahr.

30. Kadri comments (interview, 2000) that brides and grooms tend simply to fill in mahr provision in standard boilerplate contracts and rarely add specified provisions. Similarly in interviews with four Muslim family lawyers, none reported seeing any particularized contracts of this sort (Awad, interview, 2000; al-Sarraf, interview, 2000; and Kadri, inter­view, 2000).

31. Email message to Karamah responding to Marriage Contract Project announce­ment (on file with author Quraishi). Another visitor to the website expressed dismay at not having a formal marriage contract written at her wedding, and asked if it is possible to create one retroactively.

32. See

33. This is also the position of Mona Zulfikar, who spearheaded the marriage contract legislative efforts in Egypt. She says one of the most important aspects is to ‘encourage frankness, mutual understanding and dialogue between the spouses, reduce the need to have recourse to the courts in difficult and bitter litigation procedures’ (Zulfikar and al- Sadda 1996: 251; and cited in Welchman 2000: 181).

34. This is indicated by four out of the nine couples for whom one author (Quraishi) provided marriage contract information.

35.One of the brides assisted by this author (Quraishi) writes: ‘It wasn't always easy to discuss the topics of our contract but in the end the entire process has brought me and... my fiance so much closer and we have grown stronger' (personal email on file with author).

36.Quoting Samia el-Moslimany saying: ‘I put in that the burden of domestic chores was going to be shared by both of us... My father thought it was trivial, but I wanted it in the contract.’

37.See Aghili v. Saadatnejadi (1997) in which $10,000 damages was provided as a remedy to the wife if the husband breaches contract.

38.See the position paper, ‘Marriage on Islam’, at

39.Noting that over a third of the respondents reported marriages of Muslim women to non-Muslim men in their families; and noting that the number of Muslim men marrying non-Muslim women is larger.

40.‘Some Muslim women whom we interviewed expressed the opinion that the man’s freedom to marry outside the faith is neither fair nor conducive to preserving the Islamic faith in future generations born in America’ (Haddad and Lummis 1987: 146). Marquand (1996) quotes a father saying: ‘I will have a huge problem if my son marries a non-Muslim

.. and will do everything I can do to stop it.’

41.See the article, ‘Why Muslim man should not marry a non-Muslim woman’, at

42.In one extreme example, Marquand (1996) reports some members of one Muslim community sought to displace a leader whose daughters had married non-Muslims, arguing that such a failure should cause him to lose his status in the community.

43.For example, says one Muslim woman, ‘1 love the religion with all my heart, but I don’t like that the women don’t have choice’ (Todd 1997).

44.Mahmoody (1993); Not Without My Daughter, MCiM Studios, 1991. This movie depicts the true story of Betty Mahmoody’s escape from Iran with her daughter after her Iranian husband attempted to turn a two-week vacation into a permanent relocation of the family.

45.See

4G. See

47.For more information about such stereotyping, see for example Shaheen 1997. In addition, refer to the online sources of the Council of Islamic-American Relations at and the Anti-Arab Discrimination Committee which can be found at

48.Betty Mahmoody (see above note 44) has herself served as an expert witness in a few cases involving Muslim marriages (Gustafson 1991).

49.Describing a ‘traditional Muslim wedding in Walnut’, including many things not included in other Muslim ceremonies, such as dancing, singing, bride and groom sitting side by side, and the bride’s head covered.

50.Marquand (1996) quotes one Muslim saying, ‘Sometimes male domination is machismo, sometimes it is genuine faith’.

51.Winton (1993) reports the story of a severely injured Muslim woman stating that her husband believed Islam allowed him to beat her.

52.Memon (1993) provides a summary of Islamic texts (including Qur'an 4: 34) used to justify battery, showing the misinterpretations by those who do so, and urges the American Muslim community to recognize and fight against domestic violence in their community.

53. Kadri (interview, 2000) notes a conversation with a woman complaining of her son beating her but who would not complain of such actions by her husband because she believed it was his right to do so. Attorney Kamran Memon (1993) notes that some imams tell these women to be patient and pray for the abuse to end, urging them not to leave their husbands and break up the family, and not break family privacy by talking about it to others.

54. Also featured on

55. These include (as a very brief sampling) the National Islamic Society of Women in America (NISWA) ; Baitul Salaam (House of Peace) PO Box 11041 Atlanta, GA 30310; Kamilat, ; Karamah: Muslim Women Lawyers for Human Rights ; the Muslim Women’s League (who co-sponsored the Los Angeles conference of the Peaceful Families Project) ; and Muslims Against Family Violence, a project of ‘Stepping Together’

56. In Seth v. Seth (1985), a non-Muslim male had converted to Islam after a marriage contracted under US civil law and Subsequendy divorced this wife by talaq and married a Muslim woman in a Muslim ceremony. In Shikoh v. Shikoh (1958), the husband, an Indian national, declared divorce before a Brooklyn imam before witnesses, signed and sent a copy of the imam’s documentation of the declaration, entitled ‘certificate of divorce’, to the wife who was in Pakistan.

57. Little reports family lawyer Ahmed A. Patel saying that he reminds his clients who perform talaq divorces that they cannot remarry under US law.

58. Community property states in the USA include: Arizona, California, Idaho, Louisiana, Nevada, New Mexico, Texas, Washington and Wisconsin; income and property earned or acquired during marriage is divided equally between the two spouses upon dissolution, even if one spouse was the predominant source of income. Allen (1992) quotes a Minneapolis imam stating that ‘in Muslim marriages, there is no notion of community property; whatever a woman earns outside the home she may keep, but a man is obligated to support his family’.

59. One encouraging case exhibits respect by one court for a religiously-motivated provision opting out of community property laws. In Mehtar v. Mehtar (1997), ^a Connecticut court upheld a Muslim couple’s pre-nuptial agreement opting out of South African com­munity property laws (the marriage contract was executed in South Africa), stating that ‘the purpose of the agreement was to comply with principles of Muslim law held by both parties’ and holding that the requirement of financial disclosure usually required to validate such opt-out clauses in Connecticut ‘would be unfair to apply... to an agreement mutually sought to honour deeply held religious beliefs’.

60. Iran is a primary example. Ayatollah Mohsen Kadivar has been quoted as saying: ‘a woman should be paid by her husband for working in the house, for cleaning, for breast-feeding. She can even say “I don’t want to do this work, I need a servant,” and her husband has to pay for this. This is in Islam, that he has to do this’ (Walter 1999).

61. The vast majority of family law cases are never published, and therefore are largely unavailable as a subject of research. Thus, most of the cases discussed in the chapter are appellate court cases, which may or may not be representative of Muslim family litigation in the United States. Moreover, family law cases are almost always a matter of individual state jurisdiction and thus the case precedent of one state does not bind another. The review of the cases in this study does, however, provide a good idea of the established persuasive and precedential authority to which a judge might turn in evaluating future cases.

62. For example, without citation to case law, Amina Beverly McCloud (2000: 140) states that marriages of Muslim immigrants to the United States ‘have generally received the protection of the courts’ because ‘marriage contracts are understood as pre-nuptial or nuptial agreements’. Similarly, Imam Yusuf Ziya Kavakci, the imam of a Texas mosque, urges Muslims to get pre-nuptial agreements because they can be used to ‘safeguard your Islamic rights within a marriage and, if necessary, in the case of a divorce’. Sec Why You Need a Prenuptial Agreement’ at.

63. This attitude is probably culturally-influenced, Under Islamic law, once the offer and acceptance have been made (both usually included in a nikah ceremony), the couple is legally married. Because many Muslim couples sign the contract Qdtab or nikaK) at one ceremony but do not begin to live together until some later date, however, many believe themselves to be only ‘engaged’ after the nikah.

64. See (audiotape also on file with author Quraishi).

65. See NY v. Benu (1976) in which the mother was charged for contributing to the delinquency of her minor daughters, who were placed in foster care with a Muslim family, and the men who ‘married’ the girls were charged with first degree sexual assault of a child.

66. Rasmusen and Stake (1998) comment: ‘even if it does not offend public policy, courts are reluctant to enforce such terms because of the costs to the courts, the difficulty of enforcement without invading the sanctity of the marital home, and the possibility that enforcement would increase conflict within the marriage’.

67. The court elaborated: ‘the Mahr Agreement in the case at bar is nothing more and nothing less than a simple contract between two consenting adults. It does not contravene any statute or interests of society. Rather, the Mahr Agreement continues a custom and tradition that is unique to a certain segment of our current society and is not at war with any public morals’ (Odatella at 98).

68. In the cases reviewed below, for example, spouses asserting the enforceability of a Muslim marriage contract as a pre-nuptial agreement did not always succeed. In both California cases dealing with mahr claims as pre-nuptial agreements, Dajani and Shaban, the court ultimately refused to honour the contract. In New York and Florida, the parties fared a bit better: in Aziz (NY) and Akileh (FL) the Muslim dower provisions were upheld, though the language of the Florida court indicates that they perceived the sadaq to be the husband’s consideration for entering into the contract, an analysis with which Awad would strongly disagree.

6g. Welchman (2000: 140) comments that a majority of jurists consider mahr to be an ‘effect of the contract’.

70. For example, Al-Khatecb (1996) includes a form titled ‘Islamic marriage contract/ pre-nuptial agreement’.

71. Pre-nuptial agreements also generally may not include provisions relating to child custody and child support.

72. Al-IIibri points out that one might just as well interpret mahr provisions as facilitating murder a Conclusion just as ludicrous as the Dajaiii'court’s conclusion regarding divorce.

73. Of course, she may be able to keep it if she goes through judicial dissolution, in which case the question of harm will be assessed by the arbiter, but this process is generally much longer and entails a burden of proof upon her.

74. fl he court refers to the entire marriage contract, rather than the dower provision only, as a sadaq.

75. Incidentally, and unfortunately, the marriage contract at issue in this case is very similar to generic boilerplate contracts distributed and used by many American mosques (samples on file with author Quraishi).

76. The court went on to say: ‘Had the trial judge allowed the expert to testify, the expert in effect would have written a contract for the parties.’

77. Later, the Florida Court of Appeals in Akileh v. Elchahal (1996), when first confronted with the question of enforceability of a Muslim marriage contract, cited Aziz v. Aziz (1985) favourably and upheld a Muslim dower provision because it found that Florida contract law applied to the secular terms of the Muslim contract. The Florida court found that, even though the husband and wife later disagreed over the meaning of the sadaq (the husband claimed that his understanding was that women always forfeited the mahr if they initiated the divorce), there was a clear agreement at the outset of the marriage that sadaq was to be paid if the parties divorced, and the court honoured that agreement.

For reference back to our earlier discussion of the treatment of these contracts as pre­nuptial agreements, in the reported opinion, the New York court does not refer to the contract in Aziz as a ‘pre-nuptial agreement’, but in Akileh (1996), the Florida court refer­ences Aziz as a case enforcing the sadaq as a pre-nuptial agreement.

78. Moreover, it might be argued that a rationale for the institution of the deferred mahr provision is the fact that most husbands will be better placed to pay high amounts later on in their careers, also part of the rationale for community property laws.

79. Shaban happened to involve a very low mahr amount and thus it was the husband who sought enforcement of the marriage contract. The court went so far as to say that the wife performed under the contract by entering into the marriage, and this constituted sufficient consideration on her part.

80. For a comparative view of the judicial treatment of mahr in Germany, see Jones- Pauly (1999)∙ For analysis of Muslim marriage cases in the UK, see Freeland and Lau (forthcoming); and Pearl (1985-86, 1995).

81. See Aghili v. Saadatnejadi (1997), 786 (likening sadaq to maintenance); Akileh υ. Elchahal (1996), 247 {sadaq is a postponed dower that protects the woman in the event of a divorce); Dajani v. Dajani (1988), 872 (commenting that one purpose of the dower is to provide security for the wife in the event of death or dissolution, but also can be an outright gift).

82. See Aghili v. Saadatnejadi (1997), 786 n. 1 (commenting that sadaq was meant to protect the wife from unwanted divorce); Shaban (2001), n. 6.

83. See Dajani v. Dajani, 872.

84. This assertion is supported by the court’s reasoning in, for example, Maklad υ. Maklad (2001), where the court declined to give comity to an Iigyptian certificate of divorce because the wife was not present at the time the decree was issued, had no prior notice that the certificate was sought, and was given no opportunity to be heard prior to its issuance.

85. Clearly not all Muslims subscribe to this as the only legitimate means of determining custody, but classical Islamic jurists addressed custody in these terms as the safest way of determining that the child will be placed with the best custodian. Some American Muslims argue for a different rule, pointing out that this is a jurisprudential invention, not one directly dictated by the original texts (see Muslim Women’s League, ‘Divorce’). It is, how­ever, the classical Islamic custody rules that are most well known and are what is at issue in these cases (though often in modified form through modern legislation in these Muslim countries).

86. See also Adra v. Clift (1961), where the court upheld a custody decree from Lebanon.

87. Conversely, religion has been counted as a negative influence if it harms the child; see In Re Marriage of Murga (1980).

88. for an extensive discussion on the precursors to modern Muslim discourse in the area of Islamic jurisprudence, see Hallaq (1997).

89. At the second ‘Islam in America’ conference, 9—11 March 2001, at Harvard Uni­versity, one panel was titled ‘Feasibility of Muslim CourtsZTribunals in the United States’. A mainstream US television network even recently presented a fictionalized version of what one of these tribunals might look like, in an episode of the television show JAG (‘The Princess and the Petty Officer’, 14 November 2000, written by Mark Saraceni).

90. Various Muslim organizations in the United States have explored conflict resolution issues within the realm of an Islamic framework, fqr example, the Islamic Society of North America has held annual training conferences on conflict resolution. The organ­ization scheduled a conference titled, ‘Muslim Peacebuilding after 9/11’ in 2003. For more information on such efforts, see

91. In particular, when one waives the right of pursuing litigation in court, the contract must be an ‘objective manifestation of a party’s intent to be bound by the religious court’s decree and the party knowingly and voluntarily waived his rights to pursue litigation in secular court without any religious group’s interference’ (Weisberg 1992: 995).

92. For example, see the website, ‘American Muslims Intent on Learning and Activism’, at for their mission statement which states AMILA was formed in October 1992 by Muslims of college age and above to meet the spiritual, educational, political, and social needs of Muslims in the San Francisco Bay Area. We are working towards building an active American Muslim community with a strong commitment to spiritual enrichment, intellectual freedom, and community service.’ AMILAs lectures, projects and activities reflect a progressive attitude towards claiming Islam as a vibrant American identity.

93. For example, Karamah recently participated (15 October 1999) in a panel of women of faith entitled ‘Religion and World Conflict’. The event was organized by the Inter­national Women’s Forum. See ‘news and events’ section at

94. See There are also a few local city-based Muslim bar associations with similar focus, for example in Chicago and the DC area.

95.See

96. ‘On the other hand is the generation of children and grandchildren who have no emotional ties to the homeland of the fathers and find little of value in their customs which are seen as counterproductive and an impediment to the progress in the society in which they are born’ (ISIM 1998: 5).

97. As a teacher in a Muslim school, Hashim notes that parents from a specific cultural background would not allow female children to spend the night even for activities such as prayer outside of the home due to their interpretation of proper cultural gender roles. Eventually, she states, when parents were able to see that ‘the religious teachings, in fact, promoted the practice of seeking opportunities to worship God’, they did decide to allow their daughters to pursue such activities.

98. They compared statistics from 1994 with 2001 responses, noting that the proportion of mosques with separation by curtain, barrier or another room had increased to 60—66 per cent of those surveyed in 2001.

Interviews

1. Sermid al-Sarraf, family and estate planning attorney, Los Angeles, California, 8 December 2000.

2. Abed Awad, family law attorney, Nutley, NewJersey, 14 November 2000.

3. Sydney Ericson, family law attorney, Brea, California, 1 October 2001.

4. Jman Hashim, teacher in an Islamic elementary school, Chicago, Illinois, 7 December 2001.

5. Cherrefe Kadri, family law attorney, Toledo, Ohio, 5 December 2000.

6. Tayibba Taylor, editor, Azizah magazine, Atlanta, Ceorgia, 12 October 2000.