Louis v. Stirling
1:24-cv-00759
D.S.C.Mar 11, 2025Background
- Plaintiff Darryl Keith Louis, Jr. (Saddiq), a South Carolina inmate, filed suit against SCDC Director Bryan Stirling, challenging the prison grooming policy under the Religious Land Use and Institutionalized Persons Act (RLUIPA).
- Louis sought to grow a fist-length beard as required by his religious beliefs, but SCDC policy limited beards to 1/2 inch.
- Plaintiff’s earlier grievance (2015) regarding beard length was deemed moot after policy changes, but a later grievance (2023) was rejected as duplicative and not processed further.
- Plaintiff argued he had exhausted administrative remedies since his attempts to appeal or get a response from SCDC grievance staff went unanswered within the mandated timeframe.
- The Court considered motions for summary judgment (by defendant) and preliminary injunction (by plaintiff), with a magistrate judge recommending the RLUIPA claim proceed, enjoining enforcement of the grooming policy, and dismissing Plaintiff’s First Amendment claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exhaustion of Administrative Remedies (PLRA) | Exhausted all remedies by waiting for response | No step-2 grievance filed for 2023; not exhausted | Exhaustion found; administrative remedies deemed unavailable |
| Substantial Burden under RLUIPA | Grooming policy substantially burdens practice | No evidence of substantial burden/harm | Policy is a substantial burden under RLUIPA |
| Least Restrictive Means Under RLUIPA | Alternatives available; other prisons allow | Policy is least restrictive for safety/security | Defendant failed to show least restrictive means |
| Preliminary Injunction (Enjoining Policy) | Likely success, irreparable harm, equities favor | Will hinder security, open floodgates | Injunction granted; balance tips to Plaintiff |
Key Cases Cited
- Holt v. Hobbs, 574 U.S. 352 (2015) (discussed constitutionality of prison grooming policies under RLUIPA)
- Mathews v. Weber, 423 U.S. 261 (1976) (scope of district court review of magistrate recommendations)
- Diamond v. Colonial Life & Acc. Ins. Co., 416 F.3d 310 (4th Cir. 2005) (standard for reviewing magistrate reports)
- Incumaa v. Stirling, 791 F.3d 517 (4th Cir. 2015) (burden of proving substantial burden on religious exercise under RLUIPA)
- Lovelace v. Lee, 472 F.3d 174 (4th Cir. 2006) (definition of substantial burden in RLUIPA)
- Couch v. Jabe, 679 F.3d 197 (4th Cir. 2012) (removal of privileges as substantial burden under RLUIPA)
- Greenhill v. Clarke, 944 F.3d 243 (4th Cir. 2019) (grooming policies and substantial burden on religious practice)
- Moore v. Bennette, 517 F.3d 717 (4th Cir. 2008) (administrative remedies must be available to require exhaustion)