Exploring the parameters of a statute that protects the right of inmates to freely exercise their religion, a federal appeals court has ruled that a prisoner who founded a religion that requires martial arts sparring but forbids eating meat or appearing nude in front of non-members was properly barred from leading a prison congregation.

But a unanimous panel of the U.S. Court of Appeals for the Second Circuit in Keesh v. Smith, 08-2816-pr, concluded that denying the inmate his religion-mandated dietary regime might not be the “least restrictive means” to address security or administrative concerns, and remanded that issue to the court below.

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