by simply citing to the need to maintain order and security in a prison. Alvarez, 518 F.3d at 1156; Greene v. Solano County Jail, 513 F.3d 982, 989 (9th Cir.2008). In general when considering whether a policy is the least restrictive means, a party must demonstrate that it has actually considered and rejected the efficacy of less restrictive measures before adopting the challenged practice. See United States v. Playboy Entm’t Growp, Inc., 529 U.S. 803, 824, 120 S.Ct. 1878, 1892, 146 L.Ed.2d 865, 886 (2000) (finding, in the context of a First Amendment challenge to speech restrictions, that “[a] court should not assume a plausible, less restrictive alternative would be ineffective”); City of Richmond v. J.A. Croson, 488 U.S. 469, 507, 109 S.Ct. 706, 729, 102 L.Ed.2d 854, 890 (1989) (<HOLDING>); Hunter ex rel. Brandt v. Regents of Univ. of
holding that the citys minority setaside program was not narrowly tailored in part because the city had not considered whether raceneutral measures would have achieved the governments interest holding that citys enforcement of the entire state penal code would not constitute a city policy because the city was required to follow state law holding that the city had standing to challenge the formation of a water improvement district that might impede the citys expansion holding that the city had standing to challenge the constitutionality of a statute allowing certain communities within the same county as the city to incorporate as towns without the citys consent holding that a city may be held liable on account of the unconstitutional conduct of city officials only if the citys policy or custom played a part in the violation