Jarrard v. Sheriff of Polk County (11th Cir.)
Notre Dame Law School’s Lindsay and Matt Moroun Religious Liberty Clinic represented Mr. Stephen Jarrard, an Evangelist of the Church of Christ who was excluded from a county jail’s volunteer ministry program because of his views on baptism. The Clinic secured an Eleventh Circuit victory for Jarrard and later obtained an agreement allowing Jarrard to resume his ministry in the program.
The Polk County Sheriff’s Office invites and encourages members of the community to minister to inmates at the County Jail. But County officials, Sheriff Johnny Moats and former Chief Jailer Al Sharp, barred Jarrard from the Jail’s ministry program because they personally reject his views on baptism. According to Sheriff Moats, the County’s “stance” is that inmates “can wait until after release” to be baptized “since it is not a requirement for salvation.” Jarrard was told he could not return to minister in the Jail unless he stopped teaching his views on baptism.
In January 2020, Jarrard sued the County officials to challenge that exclusion. The trial court dismissed Jarrard’s First Amendment claim, and Jarrard sought review of that decision by the U.S. Court of Appeals for the Eleventh Circuit. As our Clinic made clear throughout the appeal, the First Amendment plainly prohibits government officials like Moats and Sharp from denying benefits, opportunities, or access to government facilities to a person merely because he has expressed religious views which the officials dislike.
John Meiser, director of the Clinic, argued the appeal before the Eleventh Circuit. On September 16, 2024, the court ruled in favor of Jarrard, holding that jail officials violated his clearly established First Amendment rights. The Clinic successfully defended that decision before the U.S. Supreme Court, which rejected jail officials’ request that it review the Eleventh Circuit’s decision.
In 2025, jail officials agreed to allow Jarrard to return to the jail’s ministry program and resume his ministry serving the incarcerated.
The Lindsay and Matt Moroun Religious Liberty Clinic represented Jarrard alongside Zack Greenamyre of Mitchell Shapiro Greenamyre & Funt, LLP and Gerald Weber of Atlanta.
Legal Documents
U.S. Supreme Court
Court Orders and Opinions
- Order Denying Certiorari (May 19, 2025)
Parties’ Briefs
- Jarrard's Brief in Opposition (Apr. 4, 2025)
- Sheriff Johnny Moats' Petition for Writ of Certiorari (Feb. 7, 2025)
Appellate Court (U.S. Court of Appeals for the Eleventh Circuit)
Court Orders and Opinions
- Opinion (Sept. 16, 2024)
Parties’ Briefs
- Jarrard's Reply Brief (Sept. 1, 2023)
- Sheriff Johnny Moats' Response Brief (July 12, 2023)
- Jarrard's Opening Brief (May 12, 2023)
Amicus Briefs
- Brief of Professors Michael W. McConnell, Richard W. Garnett, and Eugene Volokh in Support of Jarrard (May 19, 2023)
- Brief of The Religious Freedom Institute and the Jewish Coalition for Religious Liberty in Support of Jarrard (May 19, 2023)
Trial Court (U.S. District Court for the Northern District of Georgia)
Court Orders and Opinions
- Opinion and Order (Sept. 27, 2022)
- Opinion and Order (Mar. 30, 2021)
Pleadings
- Second Amended Complaint (Jan. 13, 2022)
- Amended Complaint (May 18, 2020)
Learn More About Our Work
- "Notre Dame Law School’s Religious Liberty Clinic Secures Return of Volunteer Stephen Jarrard to County Jail’s Ministry Program After Years of Religious Discrimination" (Dec. 18, 2025)
- "U.S. Court of Appeals for the Eleventh Circuit Rules in Favor of Prison Minister Barred from County Jail" (Sept. 26, 2024)
- "Notre Dame Religious Liberty Clinic Represents Volunteer Minister Barred from County Jail Because of His Religious Views" (Apr. 19, 2024)