United States v. Ali (8th Cir. 2012): Criminal Law Case

Appellant Amina Aden appealed her contempt citations and sentences, contending that they violated the Religious Freedom Restoration Act (RFRA).  During the Appellant’s criminal trial for providing material support to a foreign terrorist organization, the U.S. District Court for the District of Minnesota cited the Appellant for criminal contempt for repeatedly failing to stand when the court convened and recessed as required by pretrial order. This Court found that the lower court erred in evaluating the Appellant’s former contentions that standing at these times would violate her religious belief. The Court found that in the RFRA context, the district court erred by evaluating the orthodoxy and sophistication of the Appellant’s belief, instead of simply evaluating whether her practice was rooted in sincerely held religious belief.  Because the district court only applied a First Amendment analysis, it did not apply an RFRA analysis that evaluated whether the pretrial order was the least restrictive means to achieve a compelling government interest.  Therefore, the Court vacated the contempt citations and remanded to the district court to evaluate whether the pretrial order was the least restrictive means to further that or other compelling interests.

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