Former Chaplain Says Firing Stemmed From Religious Objection

TALLAHASSEE, FL – Liberty Counsel filed a response brief in a Florida U.S. District Court on behalf of former Senior Chaplain Michael Horst opposing a motion from the Florida Department of Corrections (DOC) to dismiss his case. Horst was unlawfully fired from the Madison Correctional Institute in December 2024 after seeking a religious accommodation to abstain from proctoring a female chaplain’s voluntary training in violation of his religious beliefs. Horst is asking the court to deny the motion to dismiss so his case can move forward to the discovery phase and trial.

Horst has more than 40 years of ministry experience. In this case, seeks reinstatement, a declaratory judgment that his firing was unconstitutional, and damages for violations of federal and state law, including Title VII of the Civil Rights Act, the Florida Religious Freedom Restoration Act, and the First and Fourteenth Amendments.

Horst’s religious beliefs prohibit him from facilitating female ministers teaching Scripture or preaching to men. He simply requested that another qualified employee assume the role of proctoring the female chaplain’s training—a solution he asserts would have caused no undue hardship. The lawsuit states that the Florida DOC retaliated against him for asserting his rights to equal protection and religious exercise and failed to engage in the legally required interactive accommodation process.

According to the lawsuit, Horst had served without incident and proposed multiple alternative solutions, but prison officials rejected them, pressured him to change his religious views, and ultimately terminated him.

While the Florida DOC argues Horst’s lawsuit should be dismissed as a “shotgun pleading” which is a very vague and broad complaint, the response notes that Horst provided extensive factual details with distinct legal claims.

Liberty Counsel argues that the Florida DOC displayed unconstitutional “hostility” toward his religious beliefs, pointing to sworn statements that officials would not have hired him had they known his theology and that the agency allegedly refuses to hire others who hold similar convictions.

The response argues this constitutes impermissible religious favoritism and hostility under the Establishment Clause. The brief also argues Horst’s firing was related to discussions where he expressed his religious interpretation of the Bible with supervisors, which qualify as protected speech under the First Amendment for which there cannot be any reprisal.

“Defendants insist, for several pages, that [Horst’s] speech was a part of his job duties and thus unprotected, but that argument holds no water,” reads the response brief. “[Horst’s] speech…occurred behind closed doors, not in the pulpit of MCI’s chapel, not to inmates, and not in furtherance of protecting the religious liberties of the inmates under his spiritual care.”

Horst’s “well-pleaded complaint” shows he sought a modest religious accommodation and was engaged in expression protected by the First Amendment whereby his firing was clearly a result of unconstitutional discrimination and retaliation, concluded Liberty Counsel.

Liberty Counsel Founder and Chairman Mat Staver said, “Chaplain Michael Horst was an effective, long-time Chaplain and all it took was a religious accommodation request for his employer to punish and remove him. Title VII mandates reasonable accommodation of religious beliefs. Prison officials cannot fire a chaplain for refusing to violate his religious beliefs or for exercising his rights under the law. Viewpoint discrimination violates the First Amendment and religious discrimination violates Title VII.”

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