10th Circuit: Church of the Creator Does Not Qualify As A "Religion"

In Hale v. Federal Bureau of Prisons, (10th Cir., Jan. 7, 2019), the U.S. 10th Circuit Court of Appeals, in a prisoner free exercise case, held that the white supremacist Church of the Creator does not qualify as a "religion".  Thus the protections of the Religious Freedom Restoration Act do not apply to claims of an inmate whose participation in Creativity was limited because of its designation as a security threat group. The court applied a 5-factor test set out in earlier cases to determine whether Creativity was a religious belief system.  The court said in part:

Instead of addressing existential, teleological, or cosmological matters, Creativity presents only a singular concern of racial dominance, framed in terms of social, political, and ideological struggles. Thus, Creativity does not address ultimate ideas.