In Conner v. Tilton, 2009 U.S. Dist. LEXIS 111892 (ND CA, Dec. 2, 2009), in a decision unusually detailed in its analysis for a case brought by a prisoner pro se, a California federal district court held that the White supremacist Creativity Movement is not a “religion” for purposes of the First Amendment or RLUIPA. In the case, an inmate sought the right to practice various aspects of his purported religion in Pelican Bay State Prison. In deciding the case, the court relied on the definition of “religion” articulated by the 3rd Circuit in Africa v. Pennsylvania:
WeedPress: The Paper Trail 