In an action against prison administrators under the Religious Land Use and Institutionalized Persons Act (RLUIPA) for forcibly shaving plaintiff's head in violation of his religious beliefs, summary judgment for defendants is reversed in part where they failed to meet their burden to show that their policy of forcible grooming was the least restrictive means to further a compelling governmental interest.
Argued: May 14, 2009
Decided: July 31, 2009
Opinion by Judge Michael
Cecily Elizabeth Baskir, Georgetown University Law Center, Washington, DC