In Muhammad v. Crosby, the Florida Court of Appeal decided on Nov. 7 that a Muslim inmate's claim under Florida's Religious Freedom Restoration Act could move forward. The inmate , Akeem Muhammad, challenged prison rules requiring him to be clean shaven, arguing that this substantially burdens his exercise of religion. The court reversed the trial court's holding that the case should have been brought as a declaratory judgment action rather than as a claim for mandamus. The appellate court also reversed the trial court's placing of a lien on Muhammad's prison account to pay for his filing fees.
UPDATE: On Jan. 10, 2006, the court released for publication a revised opinion reaching the same result, Muhammad v. Crosby.