Bruce Rich, an Orthodox Jewish prisoner in Florida, alleged that the Department of Corrections violated the Religious Land Use and Institutionalized Persons Act by refusing to provide a strictly kosher diet. The district court granted summary judgment to the defendants. While the appeal was pending, Florida announced a new kosher-meal policy, and the defendants argued that the claim was moot. The Eleventh Circuit rejected that argument because the policy change occurred late in the litigation and did not unambiguously eliminate the possibility that the challenged conduct would recur. RLUIPA requires a government to justify a substantial burden on religious exercise with a compelling interest and the least restrictive means of serving that interest. The court held that the defendants’ evidence about cost, administration, security, and inmate morale was too speculative and incomplete to carry that burden at summary judgment. Evidence that Florida had previously provided kosher meals and had operated a pilot program also created material questions about the asserted need for the restriction. The court reversed the summary judgment and remanded for the district court to assess the new policy and the developed record in the first instance.