Beach v. Oklahoma Department of Public Safety

Summary

The Oklahoma Supreme Court affirmed summary judgment for the Oklahoma Department of Public Safety in a challenge to the requirement that the plaintiff submit a biometric facial photograph and fingerprint to renew her driver's license. The court held that the plaintiff failed to make a prima facie showing that the requirement substantially burdened her religious exercise under the Oklahoma Religious Freedom Act. The court also concluded that the matter was moot because the plaintiff had already submitted biometric photographs and fingerprints to the Department.

Holdings

1. A plaintiff seeking relief under the Oklahoma Religious Freedom Act bears the initial burden of making a prima facie evidentiary showing that the government's action substantially burdened the plaintiff's religious exercise. Only after that showing does the burden shift to the governmental entity to demonstrate that the burden is essential to further a compelling governmental interest and is the least restrictive means of doing so.
2. Beach failed to present evidence establishing a genuine issue of material fact that the Department inhibited or curtailed her religiously motivated practice or substantially burdened her religious exercise.
3. The controversy was moot because Beach had already submitted biometric photographs and fingerprints to the Department, and the court could not grant effective relief by resolving the challenge to the biometric-photo requirement.

Questions Presented

1. Whether Beach established a prima facie substantial burden on her religious exercise under the Oklahoma Religious Freedom Act.
2. Whether the controversy was moot because Beach had already submitted biometric photographs and fingerprints to the Department, leaving no effective relief available.
3. Whether the district court properly granted summary judgment to the defendants.

Disposition

other