Forced Shaving of Dreadlocks by Prison Officials Wasn't Irie, Says 4th Circuit

By Kevin Fayle on August 04, 2009 | Last updated on March 21, 2019

The 4th Circuit ruled today that the forced grooming of a Rastafarian man's dreadlocks by South Carolina correctional officers violated his rights under the Religious Land Use and Institutionalized Persons Act.  The court simultaneously ruled that the officials had not used excessive force to restrain him, however.

Devotees of the Rastafari movement, or Rastas, typically allow their hair to grow naturally into matted clusters known as dreadlocks.  Dreadlocks have many important meanings for Rastafarians, but they generally demonstrate an individual's dedication to the faith.  Conversely, Rastas associate shaved heads with Western culture, or "Babylon", and the oppression of their spiritual lives and political freedoms.
Kevin Smith sued 26 correctional officers after they shaved his head as part of prison grooming policy.  The 4th Circuit panel overturned a district court decision in favor of the officers after the panel found that the prison had failed to show that its grooming policy was the least restrictive means to further the prison's interest.

Prison officials cited cost-savings as their reason for the policy, but never attempted to support the policy with other justifications, not even the safety considerations raised by the possiblity of hidden contraband within the large manes of dreadlocks.  Moreover, the affidavit cited by the defendants did not even mention maximum security prisoners.  Because of these deficiencies, the court ruled, the correctional officers had violated Smith's rights by shaving his head.

I'd be interested to see what the court had to say about another important part of the Rasta faith, the ritualistic smoking of marijuana.  I'd be willing to bet that any panel of federal appellate judges would likely find that a ban on drug use was well within the test the 4th Circuit used today.  It would still make for an interesting case, though.

See Also:
Smith v. Ozmint (U.S. 4th Circuit)
Haircut Violated Rights of Rastafarian Inmate (Courthouse News Service)
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