Muslim Prisoner Has Initial RLUIPA Win

In Hammons v. Jones, 2006 U.S. Dist. LEXIS 7720 (ND Okl., Feb. 14, 2006), an Oklahoma federal district court held that under RLUIPA, a "substantial burden" on religious exercise occurs "when an individual is forced to significantly modify his or her religious behavior and violate his or her religious beliefs". It found that a change in a state prison’s policy that prevented Muslim inmates from receiving religious oils for use during prayers constituted a substantial burden on plaintiff prisoner’s free exercise rights, and ordered the state to introduce any evidence it had that the restriction was in furtherance of a compelling interest and was the least restrictive means available to vindicate that interest.