The ACLU of Virginia entered an appearance in a federal lawsuit on behalf of Randy Burke, an incarcerated person within the Virginia Department of Corrections (VDOC). Mr. Burke is a practicing Rastafarian who was put in solitary confinement for over five years for refusing to cut his hair, even though cutting his hair would violate a tenet of his religion. During his time in solitary confinement, he was also denied opportunities to practice his religion, including receiving religious services, religious items, and holiday meals. 

Mr. Burke was originally incarcerated in the Virgin Islands and was transferred to Red Onion State Prison in April 2013 and later to Wallens Ridge State Prison in May 2014, where he was held in the “Violators Housing Unit,” confined to a solitary cell for 21 hours a day, until the unit closed in 2019. He filed a lawsuit against VDOC in August 2016 after exhausting the prison’s grievance system with no relief. After initially losing his case in the trial court, Mr. Burke obtained representation from the Appellate Clinic at Washington University School of Law and successfully urged the Fourth Circuit Court of Appeals to reverse the trial court’s decision.  


Eden Heilman, Matthew Callahan, Monique Gillum

Date filed

August 1, 2016


Western District of Virginia


Pamela Sargent



Case number