In Norwood v. Strada, (3d Cir., Sept. 25, 2007), the U.S. 3rd Circuit Court of Appeals affirmed a lower court's dismissal of a claim by a Muslim held in a federal prison that his religious freedom rights protected by RFRA were violated when he was denied a religiously acceptable Halal diet for 3 days during an emergency prison lock-down.
In Keith v. Hawk-Sawyer, 2007 U.S. Dist. LEXIS 72597 (SD IL, Sept. 28, 2007), an Illinois federal district court dismissed a prisoner's attempt to get the federal Bureau of Prisons to recognize the Christian Identity religion. It found no case or controversy as to some of the defendants, and held the case was moot as to others.
In Williams v. Miller, 2007 U.S. Dist. LEXIS 72552 (SD IL, Sept. 28, 2007), an Illinois federal district court held that whether a prisoner was sincere in his attempt to have his religious affiliation changed from Catholic to Jewish in prison records poses factual issues that cannot be decided in a motion for summary judgment. Only by getting his religious designation changed could plaintiff obtain kosher meals and Jewish religious texts and accessories.
In Jones v. Shabazz, 2007 U.S. Dist. LEXIS 72640 (SD TX, Sept. 28, 2007), a Texas federal district court rejected almost all of the many claims raised by a Nation of Islam prisoner who complained that Texas prison chaplains and administrative officials denied him and other NOI inmates access to religious videotapes, DVDs, books, newspapers, and prayer oil; that they refused to accommodate religious practices as to diet, charity and modesty, and the use of plaintiff's religious name; and that they discriminated against NOI inmates in hiring of chaplains and furnishing religious services. Only the prayer oil claim and a claim regarding a requirement that plaintiff stand nude after strip searches and showers survived immediate dismissal.
In Hunt v. Miller, 2007 U.S. Dist. LEXIS 73907 (ND IN, Sept. 28, 2007), an Indiana federal district court held that while "the Constitution allows jails ... to employ chaplains to provide religious services, ... the First Amendment's free exercise clause does not require small jails to hire chaplains or take other affirmative steps to assist prisoners in practicing their religion."
In Toler v. Leopold, 2007 U.S. Dist. LEXIS 73232 (ED MO, Oct. 1, 2007), a Missouri federal district court dismissed a RLUIPA claim against the Missouri Department of Corrections, finding that RLUIPA does not waive a state's 11th Amendment immunity from damage suits.
