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United States Fourth Circuit


Couch v. Jabe, 11-6560

In a suit by a Sunni Muslim incarcerated in a state correctional facility, alleging that prison officials violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) by refusing to permit him to grow a one-eighth-inch beard in compliance with the requirements of his faith, the district court's grant of summary judgment to the prison officials is vacated, where the prison officials did not explain how a one-eighth-inch beard would implicate health or security concerns, and so failed to satisfy their burden under RLUIPA of showing that the general grooming policy that they rely upon is the least restrictive means of furthering a compelling governmental interest.

Appellate Information

  • Decided 05/11/2012
  • Published 05/11/2012

Judges

  • Traxler

Court

  • United States Fourth Circuit

Counsel

  • For Appellant:
  • Jeffrey Edward Fogel, Earle Duncan Getchell, Jr.

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