6th Circuit Reverses Dismissal of Rastafarian Inmate's Diet and Fasting Claims

In Koger v. Mohr, (6th Cir., July 7, 2020), the U.S. 6th Circuit Court of Appeals reversed an Ohio federal district court's dismissal of two religious accommodation claims brought by a Rastafarian inmate. The court concluded that officials had not offered adequate justification for refusing to provide an Ital diet (organic food, vegetarian no soy).  The court also concluded that plaintiff had asserted a valid equal protection claim as to refusal to accommodate Rastafarian fasting days:

Koger stated that he “fasted during Ramadan in the past because it occasionally aligns with the fasting days observed by Rastafarianism” and because ODRC did not allow him “to fast as a Rastafarian . . . without being subject to discipline.”

The court affirmed the dismissal of plaintiff's claims as to dreadlocks and inability to commune with other Rastafarians.