summary judgment, based on an alleged failure to exhaust available administrative remedies pursuant to the Prison Litigation Reform Act of 1995, are currently in the briefing stage. See Docket No. 15 (Amended Order dated April 5, 2012). 9 . In Gladson, the Eighth Circuit acknowledged that in light of Cutter v. Wilkinson, 544 U.S. 709, 725, 125 S.Ct. 2113, 161 L.Ed.2d 1020 (2005), "portions of the definition stated in Murphy requiring religious beliefs to be a ‘central tenet’ or ‘fundamental’ may not apply to a RLUIPA claim.” 551 F.3d at 832-33 (quoting Patel, 515 F.3d at 813 n. 7) (internal quotations and alterations omitted). 10 . RFRA was declared unconstitutional as applied to the states and localities in City of Boerne v. Flores, 521 U.S. 507, 117 S.Ct. 2157, 138 L.Ed.2d 624 (1997) (<HOLDING>). See Murphy, 372 F.3d at 987. “In RLUIPA,
holding that congress had exceeded its authority by using its section five power under the fourteenth amendment to enact the statute holding that congress possesses ample authority to enact  1326 pursuant to its inherent immigration power  holding that congress exceeded its authority under  5 of the fourteenth amendment in attempting to abrogate the states eleventh amendment immunity in adea suits holding that congress may abrogate a states immunity pursuant to its enforcement power under  5 of the fourteenth amendment holding that title ii of the ada was a valid use of congress power under section 5 of the fourteenth amendment