PositionBrief Article

U.S. District Court


Tart v. Young, 168 F.Supp.2d 590 (W.D.Va. 2001). An inmate brought ?? 1983 claims against a warden and commissioner of corrections alleging they violated his free exercise rights. The district court granted summary judgment in favor of the defendants. The court held that a prison policy that prohibited inmates from "smudging" with herbs did not violate the First Amendment. The court also found no free exercise violations in the prison policy that denied the inmate access to a sweat lodge and by failing to establish Native American group meetings...

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