In Williams v. Snyder (Sept. 26, 2005), the U.S. Seventh Circuit Court of Appeals held that the trial court had applied the wrong standard in dismissing as frivolous a Rastafarian prisoner's claim that requiring him to cut his dreadlocks in order to leave his cell violated his religious free exercise of rights. The trial court's balancing of interests is appropriate only in a motion for summary judgment after additional fact finding. It is not the standard to be used for screening on the pleadings alone.
In Clark v. Briley, 2005 U.S. Dist. LEXIS 21350 (ND Ill., Sept. 26, 2005), an Illinois federal district court held that forcing a Rastafarian prisoner to cut his dreadlocks was the least restrictive means of achieving prison safety and security. His hair could serve as a hiding place of weapons or drugs, a significant risk considering this prisoner's past history. Therefore the court rejected the prisoner's claims under the Religious Land Use and Institutionalized Persons Act and under the First Amendment and granted summary judgment to the defendants.
