In Altman v. Minnesota Department of Corrections, the United States Court of Appeals for the Eighth Circuit rejected a free exercise challenge brought by a group of prison guards who were reprimanded for reading their Bibles in protest during a mandatory training entitled “Gay and Lesbians in the Workplace.” Because of their reprimands, the guards were ineligible for promotions for the next two years. The guards contended that they were denied their promotions for exercising their religious beliefs in violation of the Free Exercise Clause. The Eighth Circuit noted that the government significantly burdens the exercise of religion if it constrains conduct or expression that manifests a central tenet of a person's religious beliefs. One form of significant restraint occurs when the government conditions receipt of an important benefit, such as employment, upon conduct proscribed by a religious faith, or denies such a benefit because of conduct mandated by religious belief. However, the court found no significant burden here, because the guards did not contend that they were mandated by their religion to read their Bibles at work. Further, the warden explicitly stated that the training was not meant to tell anyone what to believe. Thus, the only burden on the guards’ religion was attending the training itself, which the court found insignificant.
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