Horani, Sohayla

In March 2026, Dr. Sohayla Horani, a surgical resident went to the D.C. Department of Motor Vehicles (“DMV”) to obtain a D.C. driver’s license. What should have been a routine appointment turned into a violation of the fundamental right to religious freedom: In order to receive her driver’s license, DMV staff forced Dr. Horani to pull back her hijab to reveal her hair, in violation of her religious beliefs. In doing so, DMV staff violated a federal law, the Religious Freedom Restoration Act of 1993 (“RFRA”), and D.C.’s own policy stated on the DMV’s website that hair does not need to be shown in ID photographs.

When DMV staff told Dr. Horani she needed to pull back her hijab and show her ears or some of her hair at the hairline for her driver’s license photograph, Dr. Horani resisted. She explained that she is not allowed to show any hair as a matter of religious conviction, and she showed her U.S. passport and Oregon ID photographs where she was not required to show any hair at all as evidence that she had never been asked to do this before for any other government-issued ID. The employee responded that it did not matter, that “these are our rules,” and that they do this every day, including to other women who wear a hijab. The employee’s supervisor confirmed that if Dr. Horani refuses to pull back her hijab and show her hair for the photograph, she would not get an ID.

After all of Dr. Horani’s objections were rejected and left with no other choice, she ultimately complied, resulting in a driver’s license that was completely useless to her because it shows her hair and it is strictly against Dr. Horani’s religious beliefs to show her hair to any man who is not her husband or close blood relative.

We submitted a pre-suit settlement demand letter to D.C. on Dr. Horani’s behalf. In the letter, we explained that Dr. Horani is considering pursuing a lawsuit under RFRA and that she would successfully state a RFRA claim because she would be able to show that the District substantially burdened her exercise of religion by requiring her to violate her sincerely held religious beliefs in order to obtain an ID. The letter stated that Dr. Horani is willing to refrain from filing a lawsuit if the District agrees to take steps to rectify the situation, including permitting Dr. Horani to retake her driver’s license photograph free of charge, destroying all electronic and paper copies of the photograph showing her hair, and training DMV employees on D.C.’s policy.

The same day we sent the letter, D.C. responded favorably, agreeing to each of these conditions. D.C. DMV noted that it “takes this matter seriously and will require additional training on the issuance of credentials without violating an individual’s religious beliefs.”