between sunset and dawn to enable daytime fasting during Ramadan. But the Makin plaintiffs confinement in punitive segregation meant that his meals were delivered only during daylight hours. The Tenth Circuit affirmed the district court’s finding that this arrangement violated Makin’s First Amendment rights, because even though Makin was still able to observe the Ramadan fast by saving crackers and other nonperishable items from the meals delivered during the day and consuming them after sunset, having to take such measures “substantially as pursued his claims pro se and IFP, and given the possibility that his complaint might be amended or construed to state a claim under RLUIPA, a statute that may present complex legal issues, compare Cutter v. Wilkinson, 349 F.3d 257 (6th Cir.2003) (<HOLDING>), with Madison v. Riter, 355 F.3d 310 (4th
holding that establishment clause claim need not be predicated on coercion holding that rluipa violates establishment clause holding that establishment of christmas day as legal public holiday did not violate establishment clause holding no violation of federal establishment clause holding that the statute as applied violates the commerce clause