In Dorman v. Aronofsky, the United States Court of Appeals for the Eleventh Circuit addressed whether an inmate’s constitutional and statutory rights were violated when the county jail prohibited him from participating in the Jewish Passover celebration due to the inmate’s failure to punctually register. The plaintiff, inmate Bradley Dorman, filed a claim against two chaplains of the Broward County Main Jail, alleging that the chaplains violated his rights under the Religious Land Usage and Institutionalized Persons Act (“RLUIPA”), the First Amendment, and the Fourteenth Amendment.
The Eleventh Circuit held that the jail’s requirement that inmates register forty-five days prior to Passover did not substantially burden the inmate’s exercise of religion under RLUIPA. In addition, the notice of the new registration timeline given by the chaplains did not violate the Due Process Clause of the Fourteenth Amendment.