Bradley Dorman v. Chaplains Office BSO, et al, No. 20-10770 (11th Cir. 2022)
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Plaintiff, a Jewish inmate at the Broward County Main Jail in Fort Lauderdale, Florida, did not participate in Passover in 2018 because he failed to register 45 days prior to its celebration as required by the Jail’s policy. Proceeding pro se, he sued Broward Sheriff’s Office Chaplains under 42 U.S.C. Section 1983, alleging violations of his rights under the First Amendment, the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. Section 2000cc-1(a), and the Due Process Clause of the Fourteenth Amendment. The district court dismissed the claims with prejudice under Rule 12(b)(6).
The Fifth Circuit affirmed. The court first held the 45-day registration requirement did not constitute a substantial burden on Plaintiff’s exercise of his Jewish faith under the RLUIPA, and therefore it also did not violate the First Amendment’s more lenient reasonableness standard. Second, the electronic posting of the 45-day registration requirement on the Jail’s computer kiosk, which he and other inmates used to communicate with Jail staff, provided adequate notice of the registration requirement to satisfy due process. The court explained that if a claim fails under the RLUIPA—which embeds a heightened standard for government restrictions of the free exercise of religion—it necessarily fails under the First Amendment.
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