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One minute camp keeps that crossbreed-liberties difference can be applied only when a totally free-get it done claim was entered with different individually practical claim. See Archdiocese regarding Arizona v. WMATA, 897 F.3d 314, 331 (CADC 2018) (Good “crossbreed legal rights allege . . . requires independently feasible free address and you can totally free do it claims”); Gary S. v. Manchester College or university Dist., 374 F.three-dimensional fifteen, 19 (CA1 2004) (following Area Court’s reason one to “the fresh new [hybrid-rights] exception to this rule is invoked on condition that the latest plaintiff have inserted a 100 % free do so issue with several other by themselves viable constitutional claim,” ۲۴۱ F. Supp. 2d 111, 121 (NH parship usa 2003)); Brownish v. three dimensional 525, 539 (CA1 1995). However, this method generally makes the free-do so allege irrelevant. Look for Axson-Flynn v. Johnson, 356 F.three dimensional 1277, 1296–۱۲۹۷ (CA10 2004) (“[I]t renders no feel to adopt a strict important you to basically need a profitable companion claim due to the fact particularly a test would make new free take action allege way too many”); come across including Lukumi, 508 U. S., from the 567 (advice from Souter, J.) (making the same point). ” Pick Foundation Religious Colleges v. University Interscholastic League, 563 F.three-dimensional 127, 136, letter. 8 (CA5 2009); San Jose Religious College or university v. Morgan Mountain, 360 F.three dimensional 1024, 1032–۱۰۳۳ (CA9 2004); Axson-Flynn, 356 F. three dimensional, at the 1295–۱۲۹۷٫ Exactly what this means is hidden. Come across, age.g., id., on 1295 (writing on “helpful” analogies including the “ ‘probability of achievement into merits’ important getting first injunctions” or even the pre-Antiterrorism and Effective Death Penalty Operate basic to possess obtaining an evidentiary reading, i.elizabeth., a great “ ‘colorable showing away from factual innocence’ ”)....