Muslim Correctional Officer Trainee Loses Free Exercise Claim

In Valdes v. State of New Jersey, 2007 U.S. Dist. LEXIS 41038 (D NJ, June 6, 2007), a New Jersey federal district court dismissed free exercise and religious discrimination claims brought by Juan Valdes, a Muslim who was dismissed from New Jersey's Correctional Officer's Training Program for wearing a beard longer than one-eight inch. His religion prohibits him from shaving his beard. The court rejected Valdes' free exercise claim, holding that the grooming requirement was a generally applicable neutral regulation. It rejected Valdes' Title VII claim, finding that the state had offered him reasonable accommodation by permitting facial hair, limited in length, while usually it requires trainees to be clean shaven. The court also rejected Valdes' equal protection claim.