Nathaniel Jackson v. Michael Gilday — 4th Cir. (Oct 30, 2026)
The Fourth Circuit considers whether military prison officials can be held personally liable over a Muslim prisoner's religious beard. Nathaniel Jackson was held in a Navy brig after a military conviction and requested an exception to daily shaving rules. He alleges officials denied or delayed his request and punished him for refusing to shave, including time in disciplinary segregation. The Navy ultimately granted the exemption, but Jackson still seeks damages for the earlier burdens on his religious practice. The district court dismissed his case on qualified-immunity grounds. That defense can shield officials from personal damages even for unlawful conduct, if the law did not clearly establish the right in those circumstances. Jackson will argue that prison-religion cases and the Navy's own accommodation policy gave officials fair warning. The government will argue military detention is different from civilian prison, and the precedents did not clearly forbid what these officials did. His claim is based on the Religious Freedom Restoration Act, usually called RFRA. RFRA generally requires a substantial burden on religious practice to serve a compelling government interest, using the least restrictive means to achieve it.
Nathaniel Jackson v. Michael Gilday (No. 25-2076) — U.S. Court of Appeals for the Fourth Circuit, argued October 30, 2026.
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