# Dawud Halisi MALIK, Plaintiff-Appellant, v. Neal BROWN, Defendant-Appellee

> Court of Appeals for the Ninth Circuit · September 8, 1995 · 65 F.3d 148

URL: https://www.frixlaw.com/law-library/cases/703281

## Case

- **Full name:** 95 Cal. Daily Op. Serv. 7127, 95 Daily Journal D.A.R. 12,141 Dawud Halisi Malik v. Neal Brown
- **Court:** Court of Appeals for the Ninth Circuit
- **Decided:** September 8, 1995
- **Citations:** 65 F.3d 148; 95 Daily Journal DAR 12141; 95 Cal. Daily Op. Serv. 7127; 1995 U.S. App. LEXIS 25258; 1995 WL 529445
- **Precedential status:** Published
- **Opinion:** Opinion
- **Judges:** Beezer, Hall, Conti
- **Cited by:** 26 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/703281

## Opinion text

ORDER
Sua sponte, we recall the mandate.
Zipfel v. Halliburton Co.,
861 F.2d 565, 567 (9th Cir.1988).
It has come to the attention of the court that Congress adopted the Religious Freedom Restoration Act, 42 U.S.C. §§ 2000bb-l to 2000bb — 4 (“RFRA”), prior to the date our opinion was filed. RFRA was not called to our attention by the parties in a post-filing petition. Our research did not disclose its existence prior to filing.
RFRA sets a different standard than the one adopted in our opinion.
Malik v. Brown,
16 F.3d 330, 333-34 (9th Cir.1994). If we applied RFRA, Malik would still have been the prevailing party. This order memorializes our adoption of RFRA as the proper standard governing this case.
Upon entry of this ORDER, the mandate shall issue forthwith.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/703281. Public record. Not legal advice.