In Robinson v. Secretary, Florida Department of Corrections, (11th Cir., Nov. 4, 2026), the U.S.11th Circuit Court of Appeals affirmed the dismissal of a suit brought by a Hebrew Israelite prisoner who claims his free exercise rights were infringed when he was denied religiously compliant food for two religious holidays and when he was not permitted to reenroll in the prison's alternative meals program because he had not demonstrated the sincerity of his religious exercise. The court said in part:
Robinson argues that Chaplain Gault had a duty to correspond with FDOC’s food service department on his behalf, but he presented no evidence below to establish that the chaplain had this affirmative duty. Instead, the unrefuted evidence indicated the opposite -- that Robinson himself needed to contact food services to receive unleavened meals during Passover and failed to do so.... [This] did not “effectively” deprive Robinson of the means by which he could practice his religion and amounted to, at most, a mere “inconvenience to [Robinson’s] religious practice.”...
Nor did the court err in granting summary judgment on Robinson’s claim that he had not received a double-portion bagged lunch to break his fast at the end of the Day of Atonement in ... 2020. Robinson concedes that he was offered meal trays at breakfast, lunch, and dinner on that day.... [H]e could have retained one or all of these meals and consumed them after sundown to break his fast. On this record, we cannot say that the FDOC’s actions amounted to a substantial burden on Robinson’s religious exercise.
Robinson also challenges Chaplain Martinez’s decision to deny his reenrollment in the RDP in December 2020 -- after he had removed himself from the RDP in 2013 or 2014.... However, Chaplain Martinez’s decision did not amount to a First Amendment violation because, based on the undisputed record, it was made in accordance with FDOC’s reasonable policy for assessing admittance to the program. ...
... [T]here is a rational relationship between FDOC’s policy of assessing the sincerity of inmates’ religious beliefs and the neutral need to limit the cost and administrative burden of providing alternative meal options to inmates.... Robinson did not argue, and the evidence does not suggest, that the sole means of Robinson’s Hebrew Israelite religious expression was the receipt of a religiously-compliant diet. Rather, the FDOC Chaplaincy Services guide lists many other forms of exercise for the Hebrew Israelite faith, involving work proscription days, clothing, and worship.
