David Richardson v. Harold Clarke, No. 21-6507 (4th Cir. 2022)
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Plaintiff a deaf and blind inmate, claims he was denied the same access and enjoyment available to inmates without disabilities in violation of the Americans with Disabilities Act (“ADA”). And he contends the prison’s head covering policies substantially burdened his Islamic faith as prohibited by the Religious Land Use and Institutionalized Persons Act (“RLUIPA”).
The Fourth Circuit agreed with the district court’s order granting summary judgment to the prison on Plaintiff’s ADA claim. But vacated the district court’s order rejecting the RLUIPA claim and remanded. The court held that no reasonable factfinder could conclude on the record that the accommodations provided to Plaintiff did not afford him “meaningful access” to all programs at the prison.
However, the court found that the policy required Plaintiff to either violate his religious beliefs— by refraining from wearing a head covering at all times—or risk discipline at the prison for violating the policy. In other words, the prison’s head-covering policy placed Plaintiff between the proverbial rock and a hard place. Doing so substantially burdens his religious beliefs under the RLUIPA. Thus, the court found that Plaintiff met his burden of showing that the prior policy imposed a substantial burden. Thus, the court vacated that portion of the district court’s order and remanded for further proceedings.
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