10 Legal Cases on Religious Discrimination in Prisons

Religious freedom in U.S. prisons is guaranteed under the Religious Land Use and Institutionalized Persons Act (RLUIPA). However, inmates and staff continue to face challenges in practicing their faith. Here’s a quick summary of 10 legal cases that highlight the ongoing struggle for religious rights in correctional facilities:

Muslim Inmate’s Kufi Ban (Alaska): An inmate was denied medical treatment for refusing to remove his kufi, sparking legal action under RLUIPA.
Christian Minister Denied Access (Georgia): A Church of Christ minister was excluded from a jail program due to his beliefs about baptism.
Employee Head Covering Case (Texas): A prison employee was fired for wearing a religious head covering, leading to a federal lawsuit.
Zoning Restrictions on Churches (Georgia): A church faced zoning barriers that limited its ability to support inmates and their families.
Muslim Inmates’ Prayer Rights (Rhode Island): Inmates sued over restrictions on communal prayers and Ramadan accommodations.
Baptism Denial Settlement (Georgia): A former inmate reached a settlement after being denied baptism due to prison policies.
Religious Hair Length Rights (Georgia): A Muslim inmate won the right to grow a beard despite restrictive grooming policies.
Advocacy Group Reports (Georgia): Georgia Prisoners’ Speak documents systemic religious discrimination in state prisons.
Halal Meal Lawsuit (Georgia): Muslim inmates secured changes to meal policies during Ramadan.
Holt v. Hobbs (Supreme Court): A landmark ruling strengthened protections for religious practices in prisons.

These cases reveal the tension between prison policies and constitutional rights. Courts consistently emphasize that restrictions on religious practices must meet strict legal standards under RLUIPA.

Quick Takeaways

Religious rights in prisons are protected but often contested.
Legal victories like Holt v. Hobbs set important precedents.
Advocacy groups and lawsuits drive policy changes for fair treatment.

For more details, explore the specific cases and their broader implications.

Purpose and Protection of Religious Rights of Inmates

1. Muslim Inmate’s Kufi Ban Case – Alaska

At the Anchorage Correctional Complex (ACC), William "Jamal" Gary initially wore his kufi without issue. However, he later encountered a policy requiring him to remove it whenever he was outside his housing unit.

This policy became more than an inconvenience when Gary was denied medical treatment for a broken hand because he refused to take off his kufi. Even after offering to have his kufi inspected, Gary’s request was ignored, highlighting the arbitrary nature of the rule . Notably, other correctional facilities in Alaska permitted religious headwear, which led the ACLU of Alaska to step in . ACLU attorney Melody Vidmar emphasized the constitutional implications of the case:

"Mr. Gary’s case is a blatant example of DOC and its staff failing to meet the constitutional rights of incarcerated Alaskans. Not only were Mr. Gary’s religious requests reasonable, but they are well within his rights. Incarcerated and detained people do not leave their religion at the jailhouse doors, nor do they leave their constitutional rights behind either."

This situation mirrors similar cases across the country. For instance, on November 2, 2023, the Eighth Circuit Court ruled in favor of Abdul Maalik Muhammad, affirming his right to wear a kufi in Arkansas prisons . These cases collectively highlight the protections offered under the Religious Land Use and Institutionalized Persons Act (RLUIPA), which requires prisons to justify restrictions on religious practices by proving a compelling government interest and using the least restrictive methods .

Gary’s case brings attention to the ongoing conflict between prison security policies and constitutional rights. ACC’s policy appears to be far stricter than those at other facilities, raising questions about its necessity . This case serves as a reminder that any limitations on religious practices must align with the RLUIPA standards, ensuring they are as minimally restrictive as possible.

2. Georgia Prison Denies Christian Minister Access

In 2016, Stephen Jarrard, a Church of Christ minister, was prohibited from joining the volunteer ministry program at Polk County Jail. The reason? His belief in baptism by full immersion. Sheriff Johnny Moats and former Chief Jailer Al Sharp disagreed with Jarrard’s stance. In a 2019 statement, Sheriff Moats claimed Jarrard’s interpretation of baptism conflicted with both his own understanding of the Bible and the jail’s policy of postponing baptisms until inmates were released. This incident highlighted a growing trend of restrictive religious practices at the facility.

The jail later revised its policies to ban all religious rituals, including baptisms. This change affected not just Jarrard but also inmates like Ollie Morris, whose denied baptism led to a legal settlement.

Legal experts have consistently criticized such actions. John Meiser, director of Notre Dame’s Religious Liberty Clinic, pointed out:

"If the First Amendment stands for anything, it is that government officials may not enforce their own personal orthodoxy in matters like religion. The Sheriff may not punish Stephen and deny him the opportunity to minister to inmates simply because the Sheriff reads the Bible differently."

The U.S. Court of Appeals for the Eleventh Circuit overturned a previous ruling, stating that jail officials cannot penalize volunteer ministers for their religious beliefs. The case was sent back to district court to address Jarrard’s claims, setting a new legal standard for religious rights in Georgia prisons. Meredith Holland Kessler, a staff attorney, emphasized that excluding volunteers over denominational differences is just as discriminatory as excluding any other faith group.

This decision highlights the ongoing struggle to balance prison policies with constitutional protections for religious freedom.

3. Prison Employee Head Covering Case – Texas

The Justice Department has taken legal action against the Texas Department of Criminal Justice (TDCJ) over the firing of Franches Spears, an administrative clerk, who wore a head covering as part of her Ifa faith. Spears was terminated after refusing to remove her head covering, despite her request for a religious accommodation.

The issue arose when TDCJ applied inconsistent standards for head coverings. While other employees were allowed to wear certain types of head coverings, Spears’ religious request was denied, leading to her suspension and eventual dismissal. TDCJ also questioned the sincerity of Spears’ faith and demanded documentation from a religious institution – actions that many legal experts have labeled discriminatory.

"Employers cannot require employees to forfeit their religious beliefs or improperly question the sincerity of those beliefs. This lawsuit is a reminder to all employers of their clear legal obligation to offer reasonable religious accommodations. Employers cannot force an employee to choose between their faith and their job."
– Assistant Attorney General Kristen Clarke of the Justice Department’s Civil Rights Division

The lawsuit claims TDCJ violated Title VII of the Civil Rights Act of 1964. The Justice Department is seeking policy changes to ensure compliance with religious accommodation laws, as well as compensation for Spears’ lost wages and damages. U.S. Attorney Alamdar S. Hamdani highlighted the importance of this case, stating, "Religious discrimination in the workplace will not be tolerated in our district. TDCJ, like any other employer, must reasonably accommodate employees under Title VII of the Civil Rights Act of 1964."

In response, TDCJ’s deputy director of communications, Hannah Haney, commented, "TDCJ does not comment on pending litigation, but the agency respects the religious rights of all employees and inmates."

This case highlights the ongoing tension between workplace policies and constitutional rights, particularly in environments like prisons. It also serves as an important example of the legal protections available for religious expression in the workplace.

4. Church vs. East Point Prison Regulations

Religious discrimination can extend beyond how inmates are treated directly. In 2007, Tabernacle Community Baptist Church encountered zoning restrictions in East Point, Georgia, when the city denied its permit to establish a house of worship. The church planned to act as a religious support hub for the local community and nearby incarcerated individuals, but these regulations indirectly impacted religious support for those connected to the prison system.

The ACLU of Georgia stepped in, filing a lawsuit against the city to challenge an ordinance that barred religious groups from repurposing former commercial buildings. As a result of the legal action, the city repealed the ordinance, opening the door for religious organizations to better assist incarcerated individuals and their families .

5. Rhode Island Muslims Sue Over Prayer Rights

In February 2025, four Muslim inmates at the High Security Center in Cranston – Diamond Wilson, Karlton Brockman, Nathan Cooper, and Lorenzo Hicks – filed a lawsuit against the Rhode Island Department of Corrections (RIDOC). The lawsuit claims that RIDOC systematically denied them religious accommodations. While Christian inmates were allowed regular services, RIDOC prohibited communal prayers for Muslims. Despite having an imam on staff, Muslim inmates were repeatedly denied opportunities to meet with him and faced restrictions on accessing religious items like prayer rugs.

The lawsuit also highlights unfair treatment during religious observances. For instance, during Ramadan, inmates were reportedly given only two meals per day, with meal times that did not align with the fasting schedule. This extended their fasting periods and prevented group fast-breaking, a key aspect of Ramadan.

"As a department we acknowledge and respect the constitutional rights of everyone under our care,"

said Jhomphy Ventura, RIDOC Chief of Information. However, the lawsuit argues that RIDOC’s actions violate the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Equal Protection Clause. While RIDOC has since agreed to provide "appropriate and timely meals during Ramadan", the inmates are pushing for a permanent injunction to ensure access to religious items, communal prayers, and regular meetings with their imam. The ACLU stressed that RLUIPA prohibits imposing substantial burdens on a prisoner’s religious practice unless it’s justified by a compelling interest and executed in the least restrictive way possible .

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6. Polk County Religious Bias Settlement

Stephen Jarrard’s lawsuit against Polk County took a turn when former inmate Ollie Morris joined the case, citing his own experience of being denied a baptism request. The Sheriff argued that baptism could wait until after release, claiming it wasn’t necessary for salvation – a stance that directly conflicted with the religious beliefs of both Jarrard and Morris.

Legal experts point out that the First Amendment protects religious practices, even in correctional settings, though these rights can be limited by security concerns. This case brought attention to the ongoing challenge of balancing institutional security with the constitutional right to religious freedom.

Eventually, Morris and jail officials reached a confidential settlement. This resolution highlighted the need for prison administrators to provide reasonable accommodations for religious practices unless they can clearly justify restrictions based on security concerns.

The settlement reinforced protections for religious practices in prisons, particularly regarding rituals like baptism and access for religious volunteers. It also aligned with broader efforts to uphold religious freedoms while ensuring security within the prison system.

7. Religious Hair Length Rights Case

In 2019, the case of Smith v. Dozier brought attention to the Georgia Department of Corrections (GDOC) and its strict grooming policies. Lester James Smith, a state prisoner serving a life sentence, spent seven years in court fighting for the right to grow a beard as part of his Islamic faith.

The GDOC policy at the time limited male prisoners’ beards to half an inch, with no exceptions for religious practices. Smith, described by the court as having a "severe belief in the tenets of Islam", argued that this violated the Religious Land Use and Institutionalized Persons Act (RLUIPA).

Judge W. Louis Sands of the Georgia federal district court exposed inconsistencies in the policy. For example, female prisoners were allowed to grow their hair without restrictions, male prisoners could grow head hair up to three inches, and 37 states – including Washington D.C. and federal prisons – permitted unrestricted beard lengths.

"It is simply hard to fathom how 3 inches of hair covering the entire head is permissible, but 3 inches of hair at the bottom of the face is unworkable." – Judge W. Louis Sands

The GDOC defended its policy by citing health and safety concerns, particularly the risk of hiding contraband in beards. However, Ronald Angelone, an expert witness, pointed out that concealing contraband in beards posed no greater risk than hiding it in clothing .

The court ultimately ruled in favor of Smith, allowing eligible prisoners to grow beards up to three inches for religious reasons. This decision brought Georgia’s prison system in line with the majority of U.S. facilities that already supported religious grooming practices.

This case highlighted the ongoing tension between maintaining institutional security and protecting constitutional rights, particularly the right to religious expression. It reinforced the importance of balancing security policies with inmates’ ability to practice their faith.

8. GPS Reports on Prison Religious Rights

Georgia Prisoners’ Speak (GPS), an advocacy group focused on prison reform, sheds light on cases of religious discrimination within Georgia’s correctional facilities. Among its reports are cases like zoning disputes involving religious institutions, which highlight the broader issue of religious bias in these settings.

GPS serves as a platform for prisoners and their families to share personal accounts of religious discrimination. These stories help legal experts and civil rights advocates better understand the challenges faced within the prison system. By documenting these cases, GPS not only brings attention to past incidents but also contributes to discussions shaping current legal and policy decisions.

Federal officials have acknowledged the gravity of these issues. U.S. Attorney Ryan K. Buchanan of the Northern District of Georgia stated:

"Individuals incarcerated by the Georgia Department of Corrections should not be subjected to life threatening violence and other forms of severe deprivation while serving their prison terms."

Similarly, U.S. Attorney Peter Leary of the Middle District of Georgia highlighted the broader implications:

"We hope these findings are a wake-up call. Incarcerated people and staff in the Georgia Department of Corrections face unacceptable, systemic risks, and the impact affects all of our communities."

9. Muslim Inmates’ Food Requirements Lawsuit

In April 2022, a notable case arose at DeKalb County Jail in Georgia, highlighting the ongoing issue of accommodating inmates’ religious practices. Muslim inmates, including Norman Simmonds, were repeatedly denied Halal meals and timely meals during Ramadan. Simmonds filed a lawsuit challenging these practices, sparking attention to the broader issue.

Muslims make up about 9% of the U.S. state prison population, with some states reaching as high as 20% [12]. These numbers emphasize the importance of religious meal accommodations in correctional facilities. This case became a catalyst for legal reforms addressing such needs.

The lawsuit ended with a settlement that introduced new standards for religious accommodations at DeKalb County Jail. Key changes include:

Approving all requests for Halal-compliant meals
Delivering meals one hour before Fajr (pre-dawn prayer)
Providing meals 10 minutes before Maghrib (sunset prayer)
Announcing daily prayer times in housing units with Muslim inmates

Lena Masri, CAIR National Litigation Director, commented:

"This important settlement sends the message that religious rights will be protected and that it is important to stand up for those rights" .

Murtaza Khwaja, Executive Director of CAIR-Georgia, added:

"Prisons and jails across Georgia should take heed and examine their own Ramadan policies in light of this agreement to ensure that they are not in violation of federal law and that the constitutionally-enshrined rights of all Muslim detainees and incarcerees are protected." .

This legal victory set a strong example for other correctional facilities, reinforcing that religious dietary accommodations are a constitutional obligation. It also aligns with broader efforts to uphold religious rights in prisons, particularly in states like Michigan, New Jersey, and Pennsylvania, where Muslim inmates represent nearly 20% of the prison population .

10. Holt v. Hobbs: Prison Beard Policy Case

The 2015 Supreme Court case Holt v. Hobbs reshaped how U.S. prisons handle religious accommodations. Gregory Holt, a Muslim inmate in Arkansas, challenged the state’s Department of Correction policy that prohibited beards, except for a quarter-inch allowance for medical reasons .

Arkansas prison officials argued the ban was necessary to prevent inmates from hiding contraband or altering their appearance to evade identification . Holt, however, sought a compromise, requesting permission to grow a half-inch beard as part of his religious practice .

Justice Samuel A. Alito Jr., writing for the unanimous Court, stated:

"The Arkansas Department of Corrections policy on beards violates the Religious Land Use and Institutionalized Persons Act of 2000."

This decision established several important principles for religious accommodations in prisons:

Prison officials must prove that denying a religious exemption is the least restrictive option.
Facilities should consider accommodations that have been successfully implemented elsewhere.
Courts must critically evaluate prison administrators’ claims instead of deferring to them.
Religious protections apply to all practices, regardless of their perceived importance.

The ruling’s impact went beyond Holt’s case, strengthening protections for various religious practices. For example, it supported Native American inmates’ rights to wear long hair, influencing policies in about 80% of U.S. prison systems .

Justice Ruth Bader Ginsburg highlighted that the accommodation:

"would not detrimentally affect others who do not share petitioner’s belief."

This decision now requires prisons to provide strong justifications before restricting religious practices.

The Becket Fund pointed out that this case underscores the importance of challenging excessive restrictions on religious freedoms. Cases like Holt v. Hobbs demonstrate how targeted legal actions can push for broader systemic changes, ensuring that constitutional rights are upheld in all correctional facilities .

Conclusion

Examining legal cases within U.S. prisons highlights the ongoing challenge of balancing security needs with inmates’ constitutional rights. Prison administrators often cite safety concerns to justify religious restrictions, but the Religious Land Use and Institutionalized Persons Act (RLUIPA) sets a high bar for defending such measures. Courts require strong evidence to support these claims, ensuring that religious freedoms are not unjustly curtailed.

"An inmate’s right to exercise ‘sincerely held’ religious beliefs is balanced against governmental interests such as maintaining facility safety and order." – Gordon Graham

Legal victories in cases like Holt v. Hobbs show how focused challenges can lead to broader changes in prison systems. Organizations like Georgia Prisoners’ Speak continue to shed light on constitutional violations and push for accountability within correctional facilities.

To reduce future instances of discrimination, prisons should revisit their policies, prioritize religious accommodations, clearly document security concerns, and consider proven alternatives from other facilities. As Graham warns:

"If you do something to restrict an inmate’s free exercise of religion – whether intentionally or not – you could be penalized for violating the inmate’s constitutional rights."

Courts have firmly stated that the "mere say-so" of prison officials doesn’t suffice to justify restrictions. They stress the importance of context when applying RLUIPA standards in prison environments .