Another fed ct app holding RFRA unconstitutional as to fed govt

[Eugene Volokh]

    Patel v. United States, 1997 WL 764570 (10th Cir.) (unpublished),
rejects a *federal* prisoner's RFRA claims on the grounds that "the
Supreme Court has recently held the Religious Freedom Restoration Act
unconstitutional.  See City of Boerne v. Flores, 117 S.Ct. 2157, 2172
(1997)."  No further discussion.

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