In Cowart v. LaCasse, 2015 U.S. Dist. LEXIS 158333 (D SC, Nov. 24, 2015), a South Carolina federal district court adopted a magistrate's recommendations (2015 U.S. Dist. LEXIS 158593, Oct. 26, 2015) and dismissed an inmate's complaint that he believed the Common Fare diet which was marked kosher was in fact not kosher.
In Carpenter v. Extendicare Health Services, 2015 U.S. Dist. LEXIS 159876 D MN, Nov. 30, 2015), a Minnesota federal district court adopted a magistrate's recommendations (2015 U.S. Dist. LEXIS 160141, Oct. 26, 2015) and dismissed on various grounds12 claims, including a free exercise claim, against a private nursing home that incorrectly believed plaintiff was the subject of a court order barring him from release. The court found no state action.
In Farfan v. United States, 2015 U.S. Dist. LEXIS 160086 (SD FL, Nov. 24, 2015), a Florida federal magistrate judge recommended rejecting the claim by a federal inmate that her 144 month sentence for cocaine distribution violates RFRA because "she sincerely believes that God requires her to be at home with her family in order to properly observe holidays and rituals associated with her Catholic faith." The court responded in part: "The RFRA was enacted to encourage and protect free exercise of religion, even in a prison context. But it was never intended to be a get-out-of-jail-free card."
In McKnight v. MTC, 2015 U.S. Dist. LEXIS 160398 (ND TX, Nov. 30, 2015), a Texas federal district court adopted a magistrate's recommendation (2015 U.S. Dist. LEXIS 160775, Nov. 9, 2015), and dismissed an inmate's claim that his free exercise and RLUIPA rights were infringed by housing him with a homosexual inmate.