4th Circuit: Rastafarian Inmate Can Move Ahead With His Suit Over Solitary Confinement

Smith v. Collins, (4th Cir., July 10, 2020), is a suit by a Rastafarian inmate who spent over four years in solitary confinement for refusal to cut his hair. The inmate, Elbert Smith, says that his religion does not permit him to do so. The court, vacating the district court's dismissal of the lawsuit, said in part:

we hold that there is at least a genuine dispute of material fact as to whether Smith’s conditions of confinement imposed a significant and atypical hardship in relation to the ordinary incidents of prison life. Therefore, we vacate the district court’s summary judgment order and remand the case for further proceedings consistent with this opinion. Specifically, on remand, the district court should consider in the first instance, and after further discovery, whether the process that Smith received was constitutionally adequate and whether the Defendant-Appellees are nevertheless entitled to qualified immunity.