Shareef Childs, an inmate at Stanley Correctional Institution in Central Wisconsin, is a practicing Muslim and prays five times a day at precise times. The prison chaplains printed and distributed prayer schedules out of courtesy to the inmates, but were not obligated by the state to do so. However, Childs noticed that the prayer schedule was inaccurate and led to prayer times being off by several minutes because of the prison chaplains entering the wrong location into an online tool. While the chaplains corrected the schedule for meal deliveries during Ramadan, they did not distribute the revised prayer schedules to the inmates because of a policy that prohibits the use of government funds to purchase religious items for inmates. Childs eventually received an accurate schedule through a donation, but was unsatisfied that the prison had failed to provide him with a revised prayer schedule.
After navigating the internal grievance procedures without any success, Childs sued the correction staff in the United States District Court for the Western District of Wisconsin, where he alleged violations of the Religion Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause of the First Amendment. The district court, in its initial findings, declared that the error in the prayer schedule was not a deliberate or malicious constitutional violation. Additionally, the district court determined that neither RLUIPA nor the Free Exercise Clause required prison officials to purchase religious materials for prisoners with the use of government funds.
On March 4, 2026, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary and found that the inmate using their own funds to purchase a prayer schedule does not qualify as a substantial burden under RLUIPA. Furthermore, they found that RLUIPA does not require states to purchase religious items for inmates, which the district court declared in their summary as well. Finally, the court affirmed that the neutral prison policy did not violate the Free Exercise Clause. Ultimately, the main issue in this case is whether the correction staff at Stanley Correctional Institution is violating the rights of Shareef Childs that are supposed to be protected by RLUIPA and the Free Exercise Clause of the First Amendment.
Holt v. Hobbs (2015) and O’lone v. Estate of Shabazz (1987) relates to Childs v. Webster (2026) because they all deal with the issue of free exercise of religion of those incarcerated in the United States penal system. In Holt, Gregory Holt, also known as Abdul Maalik Muhammad, was a Salafi Muslim and asked for temporary relief from the enforcement of the Arkansas Department of Corrections’ grooming policy because he believed that growing a beard was necessary to practicing his religion. Holt believed that the grooming policy was a violation of RLUIPA, and his case eventually reached the Supreme Court, where the Court ruled, in a 9-0 majority, that the Arkansas Department of Corrections' policy on beards violates RLUIPA. Part of the majority decision was based on the fact that Holt met the standard for accommodation that was established in Burwell v. Hobby Lobby Stores Inc. (2014), where the accommodation needed to be based on a sincere religious belief.
However, in O’lone v. Estate of Shabazz (1987), the Court reached a different conclusion. In O’lone, two men, Ahmad Uthman Shabazz and Sadr-Ud-Din Nafis Mateen, sued New Jersey’s Leesburg State Prison over their workplace policies, which they believed violated their free exercise to religion that is protected under the First Amendment. The Supreme Court, in a 5-4 decision, ruled that the prison policies plausibly advanced the intended outcomes of maintaining security, order, and rehabilitation. Additionally, the majority opinion stated that while prisoners do not forfeit their rights after being convicted of a crime, the state is allowed to place necessary limitations on the rights of those incarcerated. In the dissenting opinion, the justices argued that the prison failed to properly demonstrate that the necessary restrictions placed on these inmates were needed to maintain security at the institution. Ultimately, both of these precedents are important because they provide valuable context for how the Supreme Court has decided on the issue of free exercise of religion in prisons.
From a constitutional standpoint, in Childs v. Webster (2026), I side with the United States Court of Appeals in their decision that the prison's decision not to purchase a revised prayer schedule does not violate RLUIPA or Child’s right to free exercise of religion. First, I believe that the inmate having to use their own funds to purchase a revised prayer schedule for a small fee is a minimal burden. The inmate is able to acquire a prayer schedule by their own means, so I believe the responsibility is on the inmate, not the prison, to obtain the correct prayer schedule; the prison is not restricting their right to free exercise of religion. As previously mentioned, RLUIPA does not require states to purchase religious items for inmates. Based on these facts, I believe the inmate is asking for preferential treatment rather than equal treatment. Additionally, I think O’lone v. Estate of Shabazz (1987) is the stronger and more applicable precedent to this case because of the key argument made in the Supreme Court majority opinion, which implies that the state is allowed to impose necessary limitations on the rights of incarcerated individuals. Incarcerated individuals choose to commit crimes and thus pose dangers to society, which provides the justification for the state to intervene and place necessary limitations on their rights in order to rehabilitate them and maintain safety within prisons and society as a whole. I believe courts should defer to prison administrators, like those at Stanley Correctional Institution, when it comes to their decisions about regulating prison life, as long as they provide reasonable explanations for these decisions and are not flagrantly violating the individual rights of prisoners. In the end, I think if this case were to reach the Supreme Court, the justices would reach the same opinion as the recent decision made by the United States Court of Appeals.
https://law.justia.com/cases/federal/appellate-courts/ca7/24-1817/24-1817-2026-03-04.html
https://www.oyez.org/cases/1986/85-1722
https://www.oyez.org/cases/2014/13-6827
I agree with Jack's conclusion. The issue of using government funds to provide a certain religion with access to a prayer schedule seems like preferential treatment (unless they do this with all of the prisoner's religions). O'lone v Shabazz is a perfect precedent for this case, and they ruled in favor of the prison. Ultimately, the prison officials are with the prisoners every day and their judgement is what the court should rely on.
ReplyDeleteThanks for this post Jack. I agree with your constitutional argument that the burden is minimal and that prisoners who have violated the law in the first place have to cede “some” religious rights in order to maintain order and security in the prison. The prison definitely should provide a compelling interest for restrictions and not just limit prisoners free exercise rights out of convenience. I don’t think that's what is happening here, but it does raise the question, when is the free exercise of prisoners violated and who should decide that?
ReplyDeleteIn O’lone v. Estate of Shabazz, I believe one of the facts the court got wrong was the significance that the practicing Muslims have for their Friday service. For Muslims, going to Juamu’ah is of utmost importance. The equivalent we discussed is like telling a Catholic they participate in every Catholic tradition except to go to Mass.
ReplyDeleteI agree with the conclusion that you reached in your analysis and find your points about the fee posing a minimal burden and the potential for preferential treatment to be particularly compelling. Moreover, I think that it is also important to consider that the initial prayer schedule, which contained inaccuracies, was created by chaplains out of courtesy not because it was a requirement. With this in mind, it could be argued that a corrected version being made available for a small fee supports his free exercise rights.
I agree with the Jack's argument that the prison did not violate Shareef Childs’s rights under either RLUIPA or the Free Exercise Clause. The error in the prayer schedule was an unintentional mistake rather than a deliberate attempt to interfere with religious practice, and the prison still allowed Childs to practice his faith.
ReplyDeleteI agree with you about the minimal burden associated with RLUIPA, especially given that Childs could have been able to acquire his schedule independently. However, another point against your argument is that the prison initially provided him with incorrect information which could be seen as interfering with his ability to practice his religion. Yet, even if there was no legal violation associated with the incorrect information that the prison provided to Childs, there are still some serious issues related to that agency’s overall responsibility for their errors.
ReplyDeleteI agree with your conclusion that the prison did not violate RLUIPA or the Free Exercise Clause, especially since providing prayer schedules was never a legal obligation in the first place. Since Childs was still able to obtain an accurate schedule on his own, the burden seems minimal rather than substantial. While the initial mistake is unfortunate, it doesn’t rise to the level of a constitutional violation.
ReplyDeleteI think overall, I agree with Jack's opinion on this particular case. As others have mentioned, the issue with the incorrect schedule did not seem intentional by the prison. With that fact combined with Childs ability to obtain an accurate schedule, I see no overt violation of Childs' free exercise of religion. Overall, I see this lawsuit as somewhat of a stretch given the detail's surrounding the practices of the prison and Childs' ability to solve the issue through his own action.
ReplyDeleteI think Jack's opinion on this case is very appealing and I also agree with his conclusion. Being incarcerated ultimately takes away some of the constitutional freedoms granted to us by being citizens of the United States. I don't believe that means that rights are automatically in every instance being violated, like jack said, it is inmates choice to commit a crime and the prison system is in place to keep the lives of all other citizens protected.
ReplyDeleteI agree with your opinion that the prisoners' constitutional rights were not violated by the prison. I also agree with your opinion that it is the inmate's responsibility to obtain the correct prayer schedule by their own means, not the prison's. I think that if prisons were found to be violating an inmate's First Amendment rights, and were made to supply the prayer schedule, it could lead to a slippery slope where the prison would be responsible for supplying all religious material to inmates of different religions. Supplying religious material to one religion would give preferential treatment to that religious group.
ReplyDeleteI agree with your opinion on this case. If anything, I think that prisons directly providing inmates with a prayer schedule, especially if doing so includes using government funds, leads to a slippery slope where the Establishment Clause protections are at risk. As you said in your response, when you become incarcerated, there are certain freedoms you no longer have. In this case, religious freedom is not being taken away; It is only not being directly benefited by a government institution, a prison. If there are other routes to acquiring the prayer schedule (the inmate's own funds, donations, etc.), then I do not think there is any substantial burden placed on the inmate because of their religion.
ReplyDelete