United States Court of Appeals For the Seventh Circuit
Civil Rights – prisons — religious freedom
A ban on dreadlocks in prison does not violate the Free Exercise Clause or the RLUIPA.
“The plaintiff has presented no evidence, however, either that his prison has no need to regulate hair length or hairstyle (a free-exercise claim) or that the need is not great enough to warrant interference with his religious observance (an accommodation claim). The case law recognizes the need for and validity of rules regulating the hairstyles of prisoners in the interest of security. See, e.g., Grayson v. Schuler, supra, 666 F.3d at 452, and cases cited there; Fegans v. Norris, 537 F.3d 897, 902-03 (8th Cir. 2008); Longoria v. Dretke, 507 F.3d 898, 904 (5th Cir. 2007) (per curiam); Hoevenaar v. Lazaroff, 422 F.3d 366, 369-72 (6th Cir. 2005); Hines v. South Carolina Dept. of Corrections, 148 F.3d 353, 358 (4th Cir. 1998). Although the plaintiff has identified a fellow prisoner who was allowed to wear dreadlocks similar to his, which he argues shows that the prison has no need to regulate dreadlocks, that prisoner was just receiving visitors and not going to court.”
Appeal from the United States District Court for the Northern District of Illinois, Kapala, J., Posner, J.