by C. Arlen Beam and David R. Hansen

About the authors: C. Arlen Beam and David R. Hansen are appellate judges for the Eighth Circuit Court of Appeals in St. Louis, Missouri.

Editor's note: The following viewpoint is excerpted from a 1996 court decision from the District Court for the Western District of Missouri Court of Appeals. Mark Juan Hamilton had previously filed suit against the Missouri prison officials at Potosi Correctional Center, charging that prison policies that required him to cut his hair and denied him access to a sweat lodge violated his right to free exercise of religion. The district court ruled in his favor, but the prison officials appealed, and the appeals court reversed the lower court's decision and ruled in favor of the prison policy.

Mark Juan Hamilton, an American Indian, initiated...