Does the Religious Freedom Restoration Act (RFRA) apply to protect a federal inmate's religious liberties when she has adequately pleaded a substantial burden on the practice of her Christian faith, or is RFRA protection eviscerated if a court finds that defendant-jailers' actions are reasonably related to legitimate penological interests?

Questions Presented r I. Does the Religious Freedom Restoration Act ("RFRA") and its compelling government interest/least restrictive means-test apply to protect a federal inmate's religious liberties when she has adequately pleaded a substantial burden on the practice of her Christian faith, or is RFRAprotection eviscerated if a court finds that defendant-jailers' actions are reasonably related to legitimate penological interests? II. Does qualified immunity shield rogue government officials from personal liability under RFRA or the First Amendment for taking away a prison7 er's Christian self-authored writings, because there is no case directly on point, or is her constitutional and statutory right to write so clearly established and her "freedom of opinion and its expression .. . too certain to need discussion[,]" Mutual Film Corp. v. Industrial Com., 236 U.S. 230, 243 (1915), when the defendants’ conduct serves : no legitimate penological purpose and its own policy permits inmates to write? ‘ = ee III. Is Ms. Biron's First Amendment or RFRA injunctive relief claim for vo the return of her property (144~pages of Christian writings authored . by her) moot because the writing was taken by the defendants at a different federal Bureau of Prisons facility from where she resides now, or is the claim still viable because the federal Bureau of Prisons is a single national prison system and the defendants at the prior facility remain in wrongful possession of her property and refuse to give it back? : ‘ IV. Does an appellate court get to decide in the first instance, as the , Fifth Circuit panel-majority has done, that the defendants did not substantially burden the practice of Ms. Biron's faith by halting her God-given writing assignment; and what is a “substantial burden" on religious exercise in the federal prison context? . i