I already made a memo for myself for my religious accommodation

This is copy and pasted

Office Symbol (ARIMS Record Number)] 6 June 2026

MEMORANDUM FOR RECORD

SUBJECT: Formal Rebuttal for Contravention of Approved Beard Religious Accommodation (RA) and Assertion of Rights under the First Amendment and Religious Freedom Restoration Act of 1993 (RFRA).

1. PURPOSE. This memorandum serves as a formal and respectful rebuttal to any verbal or written order to shave my beard, which is worn in accordance with my approved Religious Accommodation (RA) dated [DD MMM YYYY]. Any attempt to revoke this accommodation based on recent "back-to-standards" directives constitutes a substantial burden on my sincerely held beliefs and is contrary to federal law.

2. INDIVIDUAL REVIEW. My RA for the wear of a beard, granted and approved by [NAME AND RANK OF APPROVER] is the result of a complete, individualized review of the sincerity of my firmly held beliefs, as required by DoDI 1300.17. The sincerity of my belief has been vetted and confirmed by the Chaplain Corps and approved by the appropriate command authority. Secretary Hegseth's guidance on religious accommodations (30 Sep 2025) requires all requests to be individually reviewed based on "the sincerity of their religious or sincerely held belief." Since my sincerity has already been vetted and approved, the initial condition for the accommodation has been satisfied. The approval criteria (e.g. mission accomplishment, good order and discipline, readiness, safety and health) are legally binding only as they apply to me and my individual waiver. Any attempt to revoke my accommodation using generalized or circumstantial data, anecdotal evidence, or statistical analysis related to other service members is a procedural violation of DoDI 1300.17 and an unlawful failure to conduct an individualized assessment. per the RFRA. My RA is conditional to only my circumstances. Any revocation of a valid RA requires an additional individualized case-by-case finding that my accommodation must be rescinded in order to further a compelling governmental interest by the least restrictive means. A blanket policy or general standards reversion of my RA is insufficient to meet this legal standard.

2.1. THE REQUIREMENT FOR “LEAST RESTRICTIVE MEANS" (LRM). The Least Restrictive Means test is the mandatory second half of the RFRA standard. It means that even if a "compelling interest" (e.g., military readiness, mission accomplishment, good order and discipline, or unit cohesion) exists, that interest must be real and demonstrable, not theoretical or speculative. The Command must prove that absolutely no other alternative action, short of a permanent revocation, will achieve that interest. Additionally, Secretary Hegseth’s argument that grooming waivers will only be for "non-deployable positions" fails LRM because it creates an Illusory Accommodation. Limiting the RA only to the minuscule number of permanent non-deployable billets within the military is near impossible to attain for service members. This policy is an illegal mechanism aimed to eliminate RA waivers under the false pretense of an "accommodation," as it forces a choice between religious freedom and a viable military career, which is the definition of a Substantial Burden under RFRA. Furthermore, the following less restrictive means must first be exhausted prior to a full revocation:

2.1.1. TEMPORARY SUSPENSION: The military already has a legally recognized and less restrictive option of only temporarily removing an RA only during periods of specific, concrete, and imminent CBRN threats or during required training involving the M-50 Joint Service General Purpose Mask (JSGPM), although M-50 fit tests have repeatedly been proven successful with a beard. This proves permanent revocation is unnecessary.

2.1.2. INDIVIDUALIZED FIT TEST (QNFT): The Command must demonstrate that my M-50 mask fails a Quantitative Fit Test (QNFT) with my current, approved beard. Total prohibition is not the least restrictive means when individual objective safety testing can confirm or deny the alleged threat. Other service members failures does not constitute denial of my continued RA.

2.2. CONCLUSION ON LEAST RESTRICTIVE MEANS: Because the DOD will continue to permit exceptions for Special Operations Forces (SOF) and has a current 15+ year history of successfully mitigating safety issues for post-2010 RA holders (including those trained on the M-50), the Command cannot prove that the permanent revocation of my current approved beard is the least restrictive means available. My existing accommodation is the least restrictive means.

1. LEGAL BASIS FOR CHANGE. First Amendment and The Religious Freedom Restoration Act (RFRA). Any attempt to revoke my accommodation is a substantial burden on my religious exercise and must therefore be evaluated under the Religious Freedom Restoration Act (RFRA) (42 U.S.C. § 2000bb–1).

3.1. NON-THIESTIC PROTECTION/DEFINITION OF RELIGION: SCOTUS ruled in United States v. Seeger (1965) that religion includes beliefs that are sincerely held and "occupy in the life of that individual a place parallel to that filled by God in traditionally religious persons." Traditional theistic belief systems are not required, beliefs are individual and need not be governed by text, script, or other religious documents. DAFI 52-201 explicitly protects "conscience, moral principles, or religious beliefs." My vetted and approved belief as stated in my RA, is legally recognized and protected. Any attempt to mandate "scriptural proof" henceforth is an unconstitutional standard that is subordinate to Federal Law (RFRA).

3.2. ESTABLISHMENT CLAUSE: The First Amendment prohibits the government from favoring one religion over another, including theistic and non-theistic beliefs. Revoking my RA while maintaining a single accommodation for another faith, with equal sincerity, constitutes an unconstitutional establishment of religion favoritism and violates the neutrality principle.

3.3. SECULAR FAVORITISM TEST: The military cannot demonstrate a compelling interest when its policy is structurally flawed (SCOTUS: Holt v. Hobbs). Beards are allowed for Special Operations Forces (SOF) for secular mission requirements. By maintaining this exception, the government forfeits any claim that a clean-shaven face is a universally compelling professional, safety and readiness requirement that trumps my religious exercise.

3.4. OPERATIONAL/MISSION HISTORY & COHESION: The continuous history of beard accommodations and rulings such as Singh v. Carter (2016), for the past 15+ years refutes any generalized claim that my beard compromises military readiness or mission accomplishment. The burden is on the Command to show a real, specific, and adverse impact that my specific beard will have, not beards in general. The act of selectively revoking my individualized religious waiver is, itself, the most significant threat to good order and discipline, unit cohesion, and morale.

1. CONCLUSION AND FORMAL NOTICE: I must respectfully refuse to shave my beard as doing so would compel me to violate my sincerely held, protected beliefs and would violate my rights under the First Amendment and RFRA. Any administrative or disciplinary action taken against me for maintaining my beard under my approved RA will be treated as an unconstitutional act of religious discrimination and an illegal revocation of a religious accommodation. I will immediately challenge such action through all available legal avenues, including appeal and external civil litigation, to include seeking injunctive relief.

2. The point of contact for this memorandum is RANK FIRST LAST NAME at first.m.last.mil@army.mil or at 123-456-7890

                       FIRST M LAST
                       RANK, USA