South-Western Legal Studies in Business

Grooming Policy Must Meet State Interest And Be Applied Consistently
Description Appeals court held that where a state employee’s Rastafarian dreadlocks were in violation of the state’s grooming policy, the employee could contend that the grooming policy violated his right to freedom of religion if he could show that the policy was applied in an inconsistent manner not related to its legitimate purpose.
Topic Constitutional Law
Key Words First Amendment; Religion; Race; Grooming Policy
C A S E   S U M M A R Y
Facts Booth was a uniformed corrections officer for the state of Maryland. As a practicing member of the Rastafarian religion, and as a sign of his African identity, Booth wore his hair in dreadlocks, which violated the published grooming policy of the Department of Public Safety and Correctional Services. Refusing to abide by the regulations, he was subject to progressive disciplinary measures. Booth sued for religious and racial discrimination and for violation of his First Amendment rights of free exercise of religion. The trial court granted the employer’s motion for summary judgment; Booth appealed.

Affirmed in part, reversed in part. The Free Exercise Clause of the First Amendment forbids the adoption of laws designed to suppress religious beliefs or practices unless justified by a compelling governmental interest. An individual must comply with a valid and neutral law of general application that is narrowly tailored to achieve a compelling governmental interest. The state did not engage in racial discrimination in this instance, as the grooming policy is race neutral. However, Booth’s claim regarding violation of his freedom of religion may proceed, as there is evidence that other employees were granted exemptions from the grooming policy on grounds of religion.

Citation Booth v. State of Maryland, --- F.3d --- (2003 WL 1984454, 4th Cir., 2003)

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