“person[s]” within the meaning of the RFRA, and therefore not subject to its protection.518 Attorneys for Guantánamo detainees argue that their clients should not be deprived of the right to freedom of religion or belief as guaranteed in the First Amendment and the RFRA.519 254. The Department of Defense Directive 2310.01E on the DoD Detainee Program stipulates that all detainees should be treated humanely, and therefore be able to exercise their religion freely, “consistent with the requirements of detention”. It also forbids religious discrimination against detainees.520 c. Findings and Analysis 255. Multiple violations of the freedom of religion or belief have been reported at Guantánamo. In the past, these are said to have included the use of discriminatory detention and interrogation techniques allegedly intended to offend detainees’ religious sensitivities,521 such as the use of female interrogators performing acts aimed at taking advantage of their gender and the removal of religious items.522 Some detainees also complained that they were not allowed to have prayer mats and that they were not provided with Korans in their cells at the beginning of their detention.523 It has also been alleged that there was no imam or other Muslim chaplain assigned to Guantánamo between 2003 and 2009, thereby denying all detainees the opportunity of religious counselling.524 Other reported violations included being subjected to unnecessary forced nudity525 and forced grooming, including 518 United States Court of Appeals for the District of Columbia Circuit, Shafiq Rasul et al. v. Richard Myers, Case Nos. 06-5209, 06-5222, 11 January 2008, <http://caselaw.findlaw.com/us-dc-circuit/1078633.html>; United States Court of Appeals for the District of Columbia Circuit, Rasul v. Myers, Case Nos. 06-5209, 06-5222, 24 April 2009, <http://caselaw.findlaw.com/us-dccircuit/1422220.html>; United States Court of Appeals for the District of Columbia Circuit, Sami Abdulaziz Allaithi v. Donald H. Rumsfeld, Case Nos 13-5096, 13-5097, 10 June 2014, <http://www.lawfareblog.com/wp-content/uploads/2014/06/2014-06-10Allaithi-v.-Rumsfeld-Opinion-1.pdf>. 519 United States District Court for the District of Columbia, Hassan v. Obama, “Statement of Points and Authorities in Support of Petitioner’s Application for Preliminary Injunction”, op. cit., note 455; United States Court of Appeals for the District of Columbia Circuit, Allaithi v. Rumsfeld, , “Petition of Plaintiffs-Appellants for Rehearing En Banc”, 25 August 2014, <http://www.lawfareblog.com/wp-content/uploads/2014/08/8-25-14-Allaithi-Petition.pdf>. 520 Department of Defense Directive 2310.01E, op. cit., note 14, paras. 3.b(1)(e) and 3.b(2). 521 UN Special Procedures, “Situation of detainees at Guantánamo Bay”, op. cit., note 23, paras. 60, 91. 522 Ibid., paras. 60-61. According to this 2006 joint report of several United Nations Special Procedures mandate-holders, treatments such as the use of female interrogators performing, inter alia, lap dances during interrogations and other treatments aimed at offending detainees’ religious sensitivities were “repeatedly used”. A 2005 investigation by two general officers into FBI allegations of detainee abuse at Guantánamo found that acts designed to take advantage of female interrogators’ gender to offend Muslim males were authorized techniques. These acts included, for example, rubbing perfume on a detainee, invading their private space, leaning over them and whispering in their ears, and the wiping of fake menstrual blood on a detainee. The report however did not find evidence of a lap dance. “Army Regulation 15-6: Final Report: Investigation into FBI Allegations of Detainee Abuse at Guantanamo Bay, Cuba Detention Facility”, 1 April 2005, amended 9 June 2005 (hereinafter, “Schmidt Report”), pp. 7-8, 15-16, <http://humanrights.ucdavis.edu/resources/library/documents-and-reports/schmidt_furlow_report.pdf >. 523 “Guantanamo: Detainee Accounts”, Human Rights Watch, October 2004, p. 7, <http://www.hrw.org/legacy/backgrounder/usa/gitmo1004/gitmo1004.pdf>; ODIHR interview with Mustafa Ait Idir and Hajj Boudella, op. cit., note 217. 524 Locked Up Alone: Detention Conditions and Mental Health at Guantanamo (New York: Human Rights Watch, 2008), p. 18, <http://www.hrw.org/sites/default/files/reports/us0608_1.pdf>; “Current Conditions of Confinement at Guantánamo: Still in Violation of the Law”, Center for Constitutional Rights, 23 February 2009, p. 12, <https://ccrjustice.org/files/CCR_Report_Conditions_At_Guantanamo.pdf>. See, also, UN Special Procedures, “Situation of detainees at Guantánamo Bay”, op. cit., note 23, para. 64. 525 See, for instance, “Current Conditions of Confinement at Guantánamo”, Center for Constitutional Rights, ibid., p. 12. 110