Issue 2: If Harris makes the showing in Issue 1, burden shifts to the prison to show the burden is the least restrictive means to further a compelling government interest

Method 1: Statute

Used the 42 U.S.C.A. § 2000cc-1 statute

Then, used notes and decisions to look up "least restrictive means"

There are many cases listed. I chose to look at two that are the 1)most binding and 2) most analogous to these facts.

Case 1: Holt v. Hobbs 135 S.Ct. 853

Case 2: Native American Council of Tribes v. Weber
750 F.3d 742

Then, used notes of decisions to look up "compelling government interest"

Case 1: Jihad v. Fabian, D.Minn.2010, 680 F.Supp.2d 1021.

Case 2: Holt v. Hobbs 135 S.Ct. 853

Use Citing References

Filters: Jurisdiction, Reported cases, Supreme Court, Circuit Courts, and District Courts Notes of Decision topic: Least Restrictive Means

This returned many of the same cases that I found from my other searches. I don't find this avenue with this issue particularly helpful.

Find Secondary Resourcs

Start with Statute: Then, under citing references, filter to secondary sources and search within "halal diet"

I came across 72 C.J.S Prisons Section 92. Dietary Laws of Prisoner's religion

This source is recent (2018) and lists key cases that relate to the topic.

The key cases confirm I have found leading cases, as they are citied here.

One Good case Method

Supreme Court case Holt v. Hobbs 135 S.Ct. 853

Then, search find the headnote that applies to the "least restrictive means" (11, 12,13)

This case identifies great arguments that help to suggest what "least restrictive means indicates."

Case suggests rules for "compelling interest standards"

Petal v. U.S Bureau of Prisons

After filtering by 8th circuit and skimming headnotes, I found Muhammad v. Wheeler

Denies motion for SJ to both P and D. Useful because goes through "compelling interest" and "least restrictive means"

This was also in issue 1

While this case gives great arguments, the facts are not very close to the case at hand, and since there are others that closer resemble our case, I will probably not use this one.

At this point, seeing many of the similar cases, I am starting to recognize I have exhausted my searches here.

I did not find this as helpful because the cases were either outside of my jurisdiction or they were cases I already found.

Because Most of the cases I had found were overlapping with some of these cases in issue 2, I have fewer reflected here.

Toler v. Leopold (unpublished)

This case is a good support, although the P won. The facts are analogous to our case.