11th Circuit Rejects Hebrew-Israelite Inmate's Complaints About Diet Accommodations

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.

Prosecution Need Not Refer to Defendant by His Religious Name During His Criminal Trial

In United States v. Green, (WD VA, May 4, 2026), defendant was charged with failing to update his sex offender registration. In a pretrial motion, defendant asked that he be referred to by his Hebrew Israelite religious name--Dalayah Yashar’Al-- during his upcoming trial. Defendant contended that the failure to do so would violate his 1st Amendment free exercise rights as well as his rights under RFRA. The court said in part:

Defendant may refer to himself as Mr. Yashar’Al throughout the upcoming trial.  But the court and the government need not do so.  Even assuming Defendant has legally changed his name under Michigan common law, the name “Deon Green” may appear in records necessary to prove the government’s case.  A categorical prohibition on the court or the government from using the name “Deon Andre Green” risks confusing and misleading the jury....

... Defendant offers no argument that the court and the government’s use of his birth name in court will pressure him to modify his beliefs or to choose between his beliefs and a government benefit....

... Moreover, the government’s inclusion of Defendant’s preferred name in the indictment is an adequate religious accommodation....

... [T]o avoid confusion, the court will instruct the jury that Defendant—born Deon Green—has adopted the name Dalayah Yashar’Al, and that the two names refer to the same person....

Hebrew Israelite Student Seeks $4M In Damages For Coach's Punishment That Violated His Religious Dietary Requirements

Suit was filed yesterday in an Ohio federal district court by a Hebrew-Israelite high school football team member who was told to eat a pepperoni pizza as discipline for missing a mandatory weight class. When the student objected that eating pork was a violation of his religious beliefs, he was allowed to remove the pepperoni, but still was forced to eat the pizza with pork residue on it. The complaint (full text) in K.W. (Junior) v. Canton City School District, (ND OH, filed 12/29/2021) alleges 1st and 14th Amendment, as well as other, claims saying in part:

All Defendants were fully aware of Junior’s religious beliefs; however, Defendants established practices and implemented actions that were antisemitic and/or in direct violation of Plaintiffs’sincere religious beliefs. therefore violating 42 U.S.C. § 1983.

WHEREFORE, Plaintiffs demand compensatory damages of $3,000,000.00 and punitive damages of $1,000,000.00.... [as well as] injunctive relief....

Other dollar amounts are sought for other causes of action set out in the complaint.  WKYC News reports on the lawsuit.