United States v. Amina Farah Ali, 2012 U.S. App. LEXIS 11201

Ali was convicted by jury on 12 counts of providing material support to Al-Shabaab and one count of conspiring under 18 U.S.C. § 2339B(a)(1).
During trial, the district court cited Ali for criminal contempt twenty times for failing to stand as required by a pretrial decorum order, imposing 100 days’ jail (five days per instance).
Ali challenged the pretrial order as burdensome under RFRA; the district court denied RFRA relief and applied a First Amendment framework.
On Sept. 29–30, 2011 Ali seated herself at a final status conference; after being advised to rise, she remained seated, leading to the contempt citations.
Ali’s initial failure to rise was not challenged; after subsequent RFRA-related objections, the court considered whether RFRA applied and remanded for RFRA analysis; the court released Ali after she indicated willingness to stand in the future.

Issue	Plaintiff's Argument	Defendant's Argument	Held
RFRA applicability to pretrial court decorum orders	Ali argues RFRA requires accommodation of sincere religious beliefs.	Court applied neutral decorum rules; RFRA not considered.	Remand for RFRA analysis; first citation affirmed.
Whether RFRA requires least restrictive means balancing for the pretrial order	Ali raised RFRA to challenge burden on religion.	Court did not evaluate least restrictive means.	Remand to evaluate least restrictive means.
Scope of RFRA after first contempt	Ali contends RFRA governs subsequent contempts as well.	Contempts evaluated under RFRA framework after objection.	Vacate subsequent citations; remand for RFRA balancing.

Walker v. City of Birmingham, 388 U.S. 307 (1967) (respect for court orders unless reversed on appeal)
Howat v. Kansas, 258 U.S. 181 (1922) (court orders must be obeyed pending review)
Shell Oil Co. v. Barco Corp., 430 F.2d 998 (8th Cir. 1970) (criminal contempt respects court orders despite merits)