Carlton Fields Secures Pro Bono Victory in Landmark Religious-Rights Case for Florida Inmate

A pro bono team from Carlton Fields’ Miami office has secured a significant victory on behalf of a Florida state inmate, following a three-day federal trial establishing his right to grow a religious beard.

U.S. District Judge Rodney Smith of the U.S. District Court for the Southern District of Florida ruled that the Florida Department of Corrections (DOC) must permit inmate Sean Westley Scott — also known as Abdul Malik — to grow a fist-length beard and trim his mustache in accordance with his sincerely held religious beliefs. The court held that the DOC’s grooming policy violated the Religious Land Use and Institutionalized Persons Act (RLUIPA), a federal statute protecting the religious rights of incarcerated individuals. Although several similar challenges have been brought against the DOC elsewhere in Florida, this is the first such case to proceed to a full trial in the Southern District of Florida — underscoring the significance of the ruling for future RLUIPA claims in the circuit.

At trial, Judge Smith rejected the DOC’s contentions that the requested accommodation would compromise security, disrupt uniformity standards, hinder inmate identification, or strain institutional resources. The court's order requires the DOC to permit Scott to grow a fist-length beard and trim his mustache, with the injunction binding the DOC secretary and all officers, agents, and employees acting in concert with him.

Scott, a practicing Sunni Muslim who has been incarcerated since 2018, initiated the litigation pro se and successfully opposed the DOC’s early motions to dismiss the case before trial. After the court set the matter for trial, the Carlton Fields team stepped in through the court's volunteer attorney program to represent Scott at trial. The team was led by shareholder Aaron S. Weiss and included associates Clark Girges and Kaitlin Prece.

"Since its enactment more than 25 years ago, the Religious Land Use and Institutionalized Persons Act has been an essential safeguard for the constitutional rights of incarcerated individuals to practice their faith," said Weiss. "It has enabled Jewish inmates to maintain kosher diets, allowed Catholics to receive important sacraments, and permitted practitioners of many faiths to possess religious texts. Beyond securing Mr. Scott's rights, we believe this decision offers meaningful guidance to the DOC as it navigates similar issues going forward."

"Carlton Fields has maintained an unwavering commitment to public service throughout our 125-year history," said Amy Furness and Jay Koenigsberg, co-managing shareholders of the firm's Miami office. "Our attorneys regularly take on pro bono matters across the South Florida courts, and this case exemplifies that commitment — and our broader dedication to protecting constitutional rights."

Case: Sean Westley Scott v. Ricky Dixon, Secretary, Florida Department of Corrections, No. 2:24-cv-14064-RS (S.D. Fla. Aug. 17, 2026).

Carlton Fields Pro Bono Team: Aaron S. Weiss (Shareholder), Clark Girges (Associate), Kaitlin Prece (Associate)