In Bryson v. Page, (SD GA, September 17, 2026), a Georgia federal district court dismissed RLUIPA, Establishment Clause and free exercise claims brought against Augusta-Richmond County and against Crystal Page, Coordinator for the Richmond County Accountability Court. Georgia’s Accountability Court program facilitates treatment for drug and alcohol offenders and allows for reduced criminal sentences. Plaintiff Ivan Bryson who is Jewish was forced to participate in Christian based activities at a treatment center (Penfield) for three months until he was transferred to another facility.
Rejecting plaintiff’s RLUIPA claim, the court held that RLUIPA by its terms only applies to persons confined in a “jail, prison, or other correctional facility” and Penfield does not fall within that definition. The court said in part:
The Court finds the evidence does not support that Penfield was a jail, prison, or correctional facility under RLUIPA based on the Accountability Court DUI program and nature of the facility…. As referenced in RLUIPA, the plain meaning of the word “correctional facility” refers to a prison….
Although few courts have addressed this issue, courts generally have declined to apply RLUIPA in facilities beyond jails, prisons, or pretrial detention facilities…. Here, Plaintiff underwent treatment at a rehabilitation center following an alcohol offense as part of the Accountability Court program…. The Court refrains from broadening the meaning of an institution under RLUIPA….
The court rejected plaintiff’s Establishment Clause claim, finding that county funds were given to Penfield for a secular purpose. It rejected plaintiff’s free exercise claim, saying in part:
… [N]ot only did Defendant Page lack authority to move Plaintiff upon his initial request, but she was also unaware that Penfield would impose religious programing. As such, the Court finds that Defendant Page, in her individual capacity, did not substantially burden Plaintiff’s practice of religion.