Heidi E. Washington, Director, Michigan Department of Corrections v. James Harrison Fox, et al.
Whether the Sixth Circuit failed to give adequate deference under Cutter v. Wilkinson, 544 U.S. 709 (2005), to the Michigan Department of Corrections' compelling interest in avoiding racial unrest and violence, and in doing so, adopted a least-restrictive means analysis that forced official recognition of a white supremacist religious organization that is seeking communal worship within prison walls.
Whether the Sixth Circuit failed to give adequate deference under Cutter v. Wilkinson, 544 U.S. 709 (2005), to the Michigan Department of Corrections' compelling interest in avoiding racial unrest and violence, and in doing so, adopted a analysis that forced official recognition of a white supremacist religious organization that is seeking communal worship within prison walls