In O’Lone v. Estate of Shabazz, the Supreme Court applied the Turner v. Safley standard in the context of a free exercise challenge. In this case, a group of Muslim prison inmates brought a suit against New Jersey prison officials challenging the constitutionality of prison policies that made it impossible for the inmates to attend Friday afternoon religious services. The policies forced inmates to work outside on Fridays, which interfered with their ability to attend services during the day. The Court held that the challenged policies were reasonably related to legitimate penological interests, and therefore did not violate the Free Exercise Clause. The Court accepted the state’s argument that the policies helped to ease overcrowding in the prison building, which aided in maintaining order and security. Further, the Court found that the policies left open adequate alternative means of exercising their rights. While the inmates would not be able to attend Friday services, the Court found it enough that they were able to participate in a number of other religious ceremonies. According to the Court, the alternative means must only allow inmates some way of exercising their religious rights, which does not necessarily mean exercising them in the exact manner the inmate prefers. The Religious Land Use and Institutionalized Persons Act, passed in 2000, resulted in a significantly heightened standard that made it more difficult for the government to justify burdens on prisoner’s religious rights.
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