Lyng v. Northwest Indian Cemetery Protective Association, in 1988, denied the Yurok, Tolowa, and Karok tribes their rights to religious freedom under the first amendment by ruling in favor of the United States Forest Service.
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The Theodoratus Report was a comprehensive study prompted by the American Indian Religious Freedom Act during Lyng v. Northwest Indian Cemetery Protective Association and conducted by the United States Forest Service in order to evaluate policies and procedures to protect Native American religious cultural rights and practices.
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