4th Circuit Says Warden Has Qualified Immunity In Demotion of Rastafarian Officer

Booth v. State of Maryland, (4th Cir., July 21, 2009), involved a Rastafarian who was demoted from his position in a Maryland prison as acting lieutenant. Plaintiff alleged the demotion stemmed from dislike of the fact that he wore his hair in dreadlocks for religious reasons. The U.S. 4th Circuit Court of Appeals affirmed the grant of qualified immunity from damages to the warden who demoted plaintiff, saying that plaintiff "has failed to identify any authority to support his contention that the right to wear one’s hair in conformance with one’s religious beliefs is a clearly established constitutional right."