The following excerpt is from Malik v. Brown, 71 F.3d 724 (9th Cir. 1995):
In 1986, the Seventh Circuit generally addressed religious name changes by inmates, and specifically addressed whether prison officials were immune from liability for having refused to recognize an inmate's legal name change. Azeez v. Fairman, 795 F.2d 1296, 1301-02 (7th Cir.1986). 3 The majority assumed without discussion that Azeez's First Amendment rights were violated by the prison authorities' failure to acknowledge his religious name. See id. at 1299. The court held, however, that at the time of the violations in 1981, the law had not clearly established inmates' rights to recognition of religious names. Id.
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