Aloba v. Bureau of Prisons

Federal inmate Abdul Aloba, a practicing Muslim, sued the Bureau of Prisons after it terminated a program supplying certified halal meat and replaced it with a no-meat alternative. Aloba claimed that consuming halal meat was a sincere religious obligation, and the discontinuation imposed a substantial burden on his faith under the Religious Freedom Restoration Act. The district court granted summary judgment for the Bureau, finding no substantial burden because a non-meat diet was available. On appeal, the D.C. Circuit examined whether a triable issue existed regarding the sincerity of Aloba's belief that meat consumption was mandatory during specific meals and celebrations.

The U.S. Court of Appeals for the D.C. Circuit reversed the district court's grant of summary judgment and remanded the case, holding that the inmate presented sufficient evidence to create a genuine dispute of material fact as to whether the policy substantially burdened his religious practice.

Whether the Bureau of Prisons' termination of its halal-meat program and provision of only a non-meat alternative imposed a substantial burden on a Muslim inmate's religious exercise in violation of the Religious Freedom Restoration Act.

The decision reinforced judicial scrutiny of prison dietary policies under federal religious liberty statutes. It prompted the Bureau of Prisons to re-evaluate religious meal accommodations and signaled to correctional administrators nationwide that cost or administrative convenience could not easily override statutory protections for inmates' sincerely held religious dietary requirements.