In Howard v. Wilson, (5th Cir. April 11, 2006), the 5th Circuit Court of Appeals affirmed a Mississippi federal district court's dismissal of a prisoner's free exercise challenge to the refusal of state prison officials to recognize the prisoner's adoption of a Muslim name. The appeal was dismissed as frivolous.
In Mark v. Off, (WD Wis., March 31, 2006), a Wisconsin federal district court rejected a former state prison inmate's free exercise claims brought under the First Amendment and RLUIPA. Mark Off variously claimed he was a Wiccan, a pagan, and a ritual magician. He brought suit challenging prison officials' removal of his "magic seals" from his cell walls and door.
In Keesh v. Smith, 2006 U.S. Dist. LEXIS 18834 (ND NY, March 2, 2006), a New York federal district court refused to issue a preliminary injunction to require New York correctional authorities to accommodate two prisoners' requests to practice the religion of "Tulukeesh". One of the prisoners identifies himself as the "Savior and Teacher" of Tulukeesh and says its tenets and practices are set out in the book "Holy Blackness," which he authored.
In Andreola v. Wisconsin, 2006 U.S. Dist. LEXIS 19123 (ED Wis., April 4, 2006), a lawsuit that has already been up to the 7th Circuit once, a Wisconsin federal district judge issued orders clarifying the remaining issues in a prisoner's lawsuit seeking greater accommodation of his request for kosher food than Wisconsin authorities are willing to grant. The court rejected plaintiff's claim under the First Amendment, but found that a claim under the higher standard of RLUIPA remains.
