The following excerpt is from Hearns v. Gonzales, 1:17-cv-00038-AWI-GSA-PC (E.D. Cal. 2020):
A substantial burden exists where the state "put[s] substantial pressure on an adherent to modify his behavior and to violate his beliefs." Thomas v. Review Bd. of Ind. Employment Sec. Div., 450 U.S. 707, 717-18 (1981). A short term intrusion does not constitute a substantial burden. Canell, 143 F.3d at 1212.
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