A number of prisoner free exercise decisions have recently become available. Some date back a few months. In all of them, inmates were unsuccessful in challenging prison or halfway house rules:
In Smith v. Ozmint, 2006 U.S. Dist. LEXIS 54852 (D SC, March 31, 2006), a South Carolina federal district court accepted a Magistrate Judge's recommendation that a preliminary injunction be denied in a RLUIPA challenge to prison grooming policies by a Rastafarian prisoner.
In Wren v. Johnson, 2006 U.S. Dist. LEXIS 54183 (SD TX, July 26, 2006), a Texas federal district court dismissed an action by a Native American prisoner who alleged that he was denied the opportunity to participate in sweat lodge and pipe ceremonies.
In Grigsby v. Sims, 2006 U.S. Dist. LEXIS 55599 (SD OH, Aug. 10, 2006), an Ohio federal district court dismissed an inmate's claim that his free exercise rights were violated when he was required to work on Sundays. The inmate failed to present evidence to support his claim that he is a practicing Christian who sincerely believes that Sunday should be observed as a day of rest. UPDATE: For the Magistrate Judge's report and recommendations in the case (adopted by the court), see 2006 U.S. Dist. LEXIS 59860 (SD OH, June 28, 2006).
In Roberts v. Ozmint, 2006 U.S. Dist. LEXIS 55486 (D SC, Aug. 7, 2006), a South Carolina federal district court rejected a Hebrew Israelite prisoner's claim that forced haircuts violate his free exercise rights.
In Hastings v. Marciulionis, 434 F. Supp. 2d 585 (D WI, June 6, 2006), a Wisconsin federal district court rejected an inmate's challenge to rules of a halfway house program that prevented him from leaving to attend religious services or a Pow Wow during his first 14 days in the program and which precluded him from possessing an eagle feather at the halfway house.
