Mark Hamilton v. Dora Schriro

BEAM, Circuit Judge.

Mark Juan Hamilton, an American Indian, initiated the present action under the Civil Rights Act of 1871, 42 U.S.C. § 1983, alleging that Missouri prison officials (prison offi-ciáis) violated his First Amendment right to free exercise of religion by requiring him to cut his hair and by denying him access to a sweat lodge. Applying the Religious Freedom Restoration Act (RFRA), 42 U.S.C. § 2000bb, the district court enjoined prison officials from enforcing a hair length regulation and ordered them to provide a weekly sweat lodge ceremony. Prison officials appeal. Because the…