In Smith v. Kurmis, 2006 U.S. Dist. LEXIS 57667 (ND IN, Aug. 3, 2006), an Indiana federal district court dismissed the complaint of a pre-trial detainee who argued that placing him in administrative segregation violated his free exercise of religion by preventing him from attending religious services.
In Pinkston-El v. Snyder, 2006 U.S. Dist. LEXIS 58001 (SD IL, Aug. 17, 2006), an Illinois federal district court accepted the recommendation of a Magistrate Judge and rejected a prisoner's statutory and constitutional free exercise challenges to the Illinois Department of Corrections grooming policy. That policy prohibits "hairstyles that create a risk that contraband hidden in the hair cannot be detected or that impede searches for contraband or that pose a risk that contraband hidden in the hair may injure the employee(s) charged with searching the offender." Plaintiff Pinkston-El, a member of the Moorish Science Temple, had taken a Nazarite vow that precluded him from cutting his hair.
In Shidler v. Moore, 2006 U.S. Dist. LEXIS 58097 (ND IN, Aug. 9, 2006), an Indiana federal district court permitted a Sunni Muslim prisoner to move forward with his 1st and 14th Amendment and RLUIPA claims involving denial of prayer oil, denial of communal worship and denial of participation in Ramadan activities, as well as his complaint that classifying him as a Christian and preventing him from using his religious name on his mail prevented him from practicing his religion.
