Cases & Deals

Third Circuit reverses grant of summary judgment on First Amendment, Equal Protection, and Religious Freedom Restoration Act claims

Clients Daley, Dameon

The Third Circuit reversed a district court ruling that corrections personnel did not violate a prisoner's religious freedoms by refusing to offer him a diet that complied with his religious beliefs. Our client Dameon Daley--a federal prisoner and practicing Rastafarian--alleged that his First Amendment, Equal Protection, and statutory rights under the Religious Freedom Restoration Act were violated when prison officials failed to provide him with a meal consistent with his religious principles. The district court dismissed each of Mr. Daley's claims, primarily reasoning that Mr. Daley's religious diet is not a central tenet of the Rastafarian religion, and, as a result, the denial of such a diet could not violate his constitutional rights. On appeal, Mr. Daley argued, among other things, that the district court improperly considered whether Mr. Daley's beliefs were central to, or compelled by, his religion and that the court should only assess whether those personal beliefs are religious and sincerely held. The Third Circuit agreed and remanded the case to the district court, ordering that our client's claims be evaluated in light of the proper standard.

The case was briefed by Thomas Jones, Kevin Meacham, and Jeffrey Immel of the Pittsburgh office. Kevin Meacham argued the case in front of the Third Circuit.