The Court of Appeals for the Fourth Circuit has breathed new life into a lawsuit filed by a Baltimore County Detention Center (“BCDC”) inmate who says he was served rotten food and denied the right to practice his faith.

On July 23, 2025, in Hammock v. Watts, the Fourth Circuit reversed a lower court ruling that had dismissed Terrence Hammock’s case against BCDC officials alleging that they had served him rotten and rat-bitten food and failed to allow him to participate in religious services in violation of his constitutional rights.

The decision means Hammock will finally have a chance to prove his claims in court—with a lawyer by his side.

Hammock’s Allegations

Hammock was incarcerated at BCDC from 2019 to 2022, first as a pre-trial detainee, starting in September 2019, then as a prisoner starting in 2022. In February 2022, Hammock sued in federal district court, alleging that while he was incarcerated at BCDC, he was repeatedly served “rotten apples” and “meat with mice bites.” After getting sick several times, he stopped eating jail food altogether, losing weight as he relied on commissary snacks instead. Hammock also alleges he was barred from attending Jum’ah, the mandatory Friday congregational prayer for Muslims. Despite following procedures to request access, Hammock claims he was shut out for his entire detention, even before and after the height of the COVID-19 pandemic.

The district court dismissed Hammock’s complaint. The court concluded that Hammock’s allegations that rotten apples and rat-bitten meat served to him and other prisoners had made him sick and caused him to lose weight because he refused to eat the food were not enough to state an Eighth or Fourteenth Amendment claim against the defendants. As to Hammock’s claim that BCDC officials denied him access to Jum’ah services, the district court concluded “the legitimate penological interests of protecting [ ] health and safety” justified BCDC officials’ failure to hold Jum’ah services during the COVID-19 pandemic. For the time periods before and after the COVID-19 pandemic, the district court concluded that Hammock’s “status as a protective custody inmate” justified BCDC officials’ denial of Hammock’s ability to attend Jum’ah services.

The Fourth Circuit’s Ruling

The Fourth Circuit disagreed with the district court and reversed its ruling. Writing for the majority, Judge Roger Gregory held that:

• Hammock’s allegations about unsafe food, the injuries he suffered as a result of either eating the food or losing weight because he stopped eating the food, and that his complaint to defendants about the food were sufficient to state a constitutional claim.
• Hammock sufficiently alleged that Defendants barred him from practicing Jum’ah which violates the tenants of his religion.
• Although Defendants could defeat Hammock’s allegations by showing that they had a legitimate penological interest to bar him from practicing Jum’ah, the only reason Defendants offered—the need for social distancing during the COVID-19 pandemic—did not cover the period before and after the pandemic when Hammock was also barred from Jum’ah services.
• When Defendants failed to present a legitimate penological interest for the restrictions during the non-pandemic periods, the trial court erred in identifying an additional interest—Hammock’s protective custody status—that the Defendants themselves had not offered.

The Fourth Circuit also held that Defendants were not entitled to qualified immunity as to Hammock’s Eighth and Fourteenth Amendment claims about BCDC’s rotten food. The Fourth Circuit further ordered the district court to appoint counsel for Hammock when the case returns to the trial court.

Why Does This Ruling Matter?

The Fourth Circuit’s ruling clarifies the pleadings standard for Eighth and Fourteenth Amendment deliberate indifference claims and holds Defendants to their burden of putting forward a legitimate penological interest for restricting prisoners’ First Amendment right to exercise their religion. At bottom, it reinforces a simple but powerful principle: prisoners and detainees don’t lose their basic rights at the jailhouse door.

At Brown, Goldstein, and Levy, LLP we are proud to stand up for prisoners’ rights and to challenge unconstitutional conditions of confinement. Cases like Hammock’s highlight why this work is so critical: because justice should not stop at the prison gates.

Attorney Monica Basche works closely with incarcerated individuals and their families to ensure that they receive the support, guidance, and advocacy they need throughout every stage of the legal process. If you or a loved one is incarcerated, reach out to Monica today to get the help you deserve. Learn more about Monica here.