United States Fourth Circuit

In a challenge by plaintiff-inmate to a state prison's policy conditioning an inmate’s request for a religious accommodation on his possession of physical indicia of faith, summary judgment granting defendants qualified immunity on plaintiff's claims for monetary relief, and ruling that the prison's abandonment of the policy mooted the claims for equitable relief, are vacated and remanded, where: 1) defendants have failed to establish as a matter of law that the 2010 Ramadan policy, as applied to the plaintiff, did not violate his First Amendment rights; 2) defendants' alleged actions violated the plaintiff's clearly established rights, and defendants are therefore not entitled to qualified immunity; and 3) defendants failed to meet their "heavy burden" of establishing that it is "absolutely clear" the 2010 Ramadan policy will not be reinstated.

Appellate Information

• Decided 02/03/2014
• Published 02/03/2014

Judges

• GREGORY

Court

• United States Fourth Circuit

Counsel