Former Chaplain Sues FL Department of Corrections

TALLAHASSEE, FL – Liberty Counsel filed a lawsuit against the Florida Department of Corrections (DOC) on behalf of former Senior Chaplain Michael Horst, who was unlawfully fired after seeking a religious accommodation to abstain from proctoring a female chaplain’s voluntary training in violation of his religious beliefs. Horst’s religious beliefs prohibit him from facilitating female ministers teaching scripture or preaching to men. After denying his request without any consideration, prison officials gave him an ultimatum to resign or violate his religious beliefs. As a result, Horst was unlawfully fired when he declined both options.

Horst, who served at Madison Correctional Institute and has more than 40 years of ministry experience, 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.

Horst 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.

According to the lawsuit, when a female chaplain was hired, Horst informed his regional chaplain about his religious beliefs regarding ministerial work to men. Horst was told the female chaplain would oversee inmates’ dietary requirements and the chapel’s administrative tasks. However, in October 2024, the female chaplain requested to take part in voluntary training that would teach her to minister to the male inmates. Prison officials tasked Horst with proctoring that training.

When Horst requested a religious accommodation, the lawsuit states that prison officials treated the request as “insubordination” and “conduct unbecoming.” After issuing him the ultimatum, he was transferred to a different prison under the guise of an “investigation” that never occurred. Then, after he was fired, prison officials implemented the very accommodation he had proposed by having another employee proctor the female chaplain’s training.

When faced with the decision to resign or abandon his religious beliefs, Horst prayed and reflected and determined he would not resign. In response to Horst's decision, the assistant warden filed an incident report alleging that Horst’s request for religious accommodation had “the appearance of discrimination and insubordination,” reads the lawsuit.

“Instead of seriously considering the [law’s] requirements, [prison officials] unceremoniously, unconscionably, and unlawfully terminated Senior Chaplain Horst for the mere act of requesting an accommodation that the law demands,” states the lawsuit.

Rather than attempt to find a reasonable accommodation required by Title VII, the DOC opted to retaliate against Horst based on his religious viewpoint which amounts to unconstitutional discrimination, concluded Liberty Counsel.

Liberty Counsel Founder and Chairman Mat Staver said, “Title VII mandates reasonable accommodation of religious beliefs. Yet, the Florida Department of Corrections punished Chaplain Michael Horst for refusing to violate his religious beliefs and for merely requesting an accommodation. Prison officials cannot fire a chaplain for exercising his rights under the law. Constitutional rights and religious freedom do not yield to state agency supervisors. Viewpoint discrimination violates the First Amendment and religious discrimination violates Title VII.”

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