In Ram v. Lal, 2012 U.S. Dist. LEXIS 179958 (ED NY, Nov. 21, 2012), a New York federal magistrate judge denied a preliminary injunction in a suit between competing factions of a Ravidassia Temple in Woodside, New York. Among the disputes between the factions is the question of whether Ravidassia is a separate religion or is a sub-group within the Sikh religion. The suit grows out a a previous lawsuit filed in state court in which the state court disbanded the Management Committee of the Temple elected in 2009 and appointed a receiver to manage the Temple until a new election was held. Among other things, the receiver had the power to determine who could vote in the new election. Plaintiffs complain that Defendants' faction has been recruiting non-Ravidassia-- in particular, Sikhs who are not members of the Chammar/ Addharmi caste-- to become Temple members in order to bolster their chances of winning the election. The court held that members of the Defendants' faction were not state actors, and so no 1st Amendment claim lies against them. Plaintiffs failed to name the receiver or the state court as parties to the action. Moreover the injunction sought-- barring any actions contrary to the Temple's Bylaws-- was overly broad.