Last Friday, the US Ninth Circuit Court of Appeals in Warsoldier v. Woodford upheld a claim challenging the hair grooming policy in a California minimum security prison. The suit was brought under the Religious Land Use and Institutionalized Persons Act by Billy Warsoldier and sought a preliminary injunction. A Cahuilla Native American, Warsoldier's religious faith teaches that hair embodies the knowledge a person acquires during a lifetime and it may be cut only upon the death of a close relative. The court held that the California Department of Corrections failed to demonstrate that its grooming policy is the least restrictive means necessary to ensure prison safety and security. The decision was discussed in a widely published AP story on Friday.
In Carson v. Williams, 2005 U.S. Dist. LEXIS 15106 (ND Fla., July 27, 2005), a federal magistrate judge wrote an opinion giving a prisoner detailed instructions on how to amend his vague and incomplete complaint if he wishes to adequately allege violations of his religious freedom by jail officials.
