Correctional facilities are responsible for providing inmates with meals that meet basic nutritional needs. But when those meals interfere with an inmate’s sincerely held religious beliefs, the situation becomes more complex and potentially unconstitutional.
In Pendleton v. Jividen, the Fourth Circuit Court of Appeals reviewed a case involving an inmate in West Virginia who practiced the “Sufi Original Traditions” of Islam. Ricky Pendleton’s religious beliefs allowed him to eat fruits, vegetables, and certain fish—but not soy. The prison provided a standardized “religious diet” that was soy-based and designed to accommodate as many faiths as possible. Pendleton repeatedly requested a dietary accommodation, citing both religious and medical concerns, but his requests were denied. He eventually filed a lawsuit under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the First Amendment, arguing that the soy-heavy diet violated his religious rights.
RLUIPA prohibits jail officials from imposing a substantial burden on an inmate’s religious exercise unless it is in furtherance of a compelling government interest and uses the least restrictive means of achieving that interest. In this case, the court found Pendleton plausibly alleged that the prison’s refusal to accommodate his dietary restrictions forced him to choose between his faith and his health, a choice RLUIPA was designed to protect against.
The Fourth Circuit reversed the district court’s dismissal of the case and remanded it for further proceedings, emphasizing that a standardized diet does not automatically meet constitutional or statutory requirements if it substantially burdens an inmate’s religious practice.
Key Takeaways for Correctional Staff:
- Religious accommodations must be individualized. A one-size-fits-all religious diet may not meet RLUIPA standards.
- A substantial burden goes beyond inconvenience. Forcing an inmate to violate sincere religious beliefs or choose between faith and nutrition may trigger legal consequences.
- Documentation and communication matter. Facilities should ensure inmates have an opportunity to request accommodations and should respond consistently and appropriately.
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This case was recently featured in a Jail Pro lesson, providing correctional officers with practical insight into how courts interpret and apply RLUIPA. Our lessons break down real federal cases like this one, helping officers make better decisions and avoid costly legal missteps.
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