Bradley Dorman v. Chaplains Office BSO, 36 F.4th 1306

Plaintiff Bradley Dorman, a Jewish inmate at Broward County Main Jail, participated in Passover in 2017 but was denied participation in 2018 for failing to meet a 45‑day pre‑registration deadline (deadline Feb. 14, 2018; Passover began Mar. 30, 2018).
Dorman used the jail's computer kiosk to message chaplains in both years; in 2018 chaplains told him the deadline was posted on the kiosk homepage.
Dorman filed a pro se § 1983 complaint alleging violations of the First Amendment, RLUIPA, and the Due Process Clause for insufficient notice; he sought declaratory/injunctive relief and damages.
The district court dismissed the complaint with prejudice under Rule 12(b)(6), finding no substantial burden under RLUIPA/First Amendment and that kiosk posting provided adequate due process notice; amendment was denied as futile given his late (post‑holiday) request.
The Eleventh Circuit affirmed: the 45‑day registration requirement was not a substantial burden and the electronic kiosk posting was a constitutionally adequate method of notice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 45‑day registration deadline substantially burdened Dorman's religious exercise under RLUIPA (and thus the First Amendment)	The deadline effectively prevented Dorman from participating in Passover in 2018; change from 2017 shows the rule was unnecessary	The deadline is a neutral administrative requirement permitting full participation if timely requested and is an administrative convenience, not coercion	Not a substantial burden; merely an inconvenience. RLUIPA claim fails and First Amendment claim likewise fails.
Whether the kiosk posting of the deadline satisfied due process notice requirements	Dorman was unaware of the kiosk posting; notice should have been printed near the kiosk or personally provided given his prior participation	Posting the deadline on the kiosk homepage (which inmates routinely use to communicate with staff) was reasonably calculated to provide notice	Notice was adequate under Mullane; electronic kiosk posting was reasonably calculated and personal notice was not required.
Whether dismissal with prejudice and denial of leave to amend was appropriate	Dorman argued defective notice and sought relief; impliedly sought amendment	Defendants argued complaint shows he sought participation after Passover began, making amendment futile	Dismissal affirmed; leave to amend denied as futile because his request came after the holiday had begun.

Tellabs, Inc. v. Makor Issues & Rts., 551 U.S. 308 (accept factual allegations as true on review of dismissal)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (established plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (applies plausibility standard to pleadings)
Turner v. Safley, 482 U.S. 78 (prison regulations valid if reasonably related to legitimate penological interests)
Cutter v. Wilkinson, 544 U.S. 709 (RLUIPA imposes heightened protection for institutionalized persons' religious exercise)
Holt v. Hobbs, 574 U.S. 352 (substantial‑burden inquiry under RLUIPA)
Midrash Sephardi, Inc. v. Town of Surfside, 366 F.3d 1214 (11th Cir.) (examples of substantial burden)
Thai Meditation Ass'n of Ala., Inc. v. City of Mobile, 980 F.3d 821 (11th Cir. 2020) (clarifies substantial‑burden formulations)
Mullane v. Cent. Hanover Bank & Tr. Co., 339 U.S. 306 (notice must be reasonably calculated to inform interested parties)
Dusenbery v. United States, 534 U.S. 161 (due process does not require actual receipt of notice)
Sandin v. Conner, 515 U.S. 472 (prison liberty‑interest framework)