In O Centro Espirita Beneficiente Uniao Do Vegetal v. Duke, (D NM, Dec. 15, 2017), a New Mexico federal district court concluded that immigration rules which deny religious worker visas to uncompensated clergy likely place a substantial burden in violation of RFRA on the UDV sect because its theology requires non-compensation of its ministers.  The court issued a preliminary injunction requiring US Citizenship and Immigration Services to reconsider petitions for an R-1 Religious Worker Visa and an I-360 Religious Worker petition without applying those provisions of the rules that require applicants be compensated employees or part of an established missionary program.

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