The First Amendment protects people’s right to practice their religion without unnecessary government interference, but how much religious freedom do they have while they are incarcerated? Prisons have regulations that can make religious freedoms harder to accommodate.
In Roberts v. Engelke, Stephen Roberts was an inmate at Red Onion State Prison in Virginia and he practiced Sunni Islam. Robert's sincere religious belief was that he is required to follow both the Jewish Kashrut dietary laws as well as fasting during Ramadan. In 2020, Roberts requested that the prison provide meals that followed both of these requirements. However, the prison officials told him they were not able to provide meals that could accommodate both at the same time. He was told to choose between a kosher diet or to switch to another meal plan that would allow him to fast during Ramadan. Roberts tried to follow both practices by saving his meals until sunset, which caused him to get food poisoning many times.
Roberts had been receiving his meals from the prison’s Common Fare program, which was supposed to accommodate many different religious dietary restrictions. In 2019 he switched to the Orthodox Jewish Kosher Diet and when it became Ramadan he requested to continue to receive his kosher meals while also fasting during the day. Prison officials said they did not have enough time to make the changes because they would need to make a new meal plan, order food, and follow the food safety regulations. If he wanted to change back to the Common Faire meal plan to participate in Ramadan it would take six months to switch back to the kosher meal diet plan.
He sued the prison officials, arguing that they were violating the First Amendment’s Free Exercise Clause. The district court ruled in favor of the prison officials, but in July 2026, the Fourth Circuit Court of Appeals reconsidered his Free Exercise claim. The court of appeals decided that Roberts had a right to a diet that followed his sincere religious beliefs. However the court did not decide whether the prison had violated his rights. The appeals court sent the case back to the lower court to decide if the prison's actions were related to prison interests.
In 2021 the prison found a way to accommodate both of Robert's religious dietary requirements. I understand that the prison has to consider things like cost and food preparation time, however, I do not think those things should outweigh his First Amendment rights. Roberts was not asking for special treatment just because he wanted other food, but that it was his sincere religious belief that required him to follow certain diets. I think how the prison eventually accommodated him raises the question if the original restriction was necessary. I think the prison officials should have to show that their restrictions are reasonable and related to real prison concerns, like safety, instead of saying that accommodating religious practice is too difficult.
I think an important constitutional issue for this case is if the prison officials can force someone to choose between two religious practices that they sincerely believe in order to fully follow their faith. The Free Exercise Clause protects people’s ability to follow their religious beliefs. I do not think those protections should automatically disappear because they are in a prison. I think forcing someone to make the choice between his religious beliefs places a heavy burden on his religious freedoms.
This case relates to the ruling in Employment Division v. Smith, where the Supreme Court held that neutral laws that apply to everyone normally do not violate the Free Exercise Clause just because they place a burden on religious practices. Even though the content of the cases are different, I think it raises a question of how much power the government should have to interfere with religious practices and how much until it places too much of a substantial burden on those practices.
In the end, I think the prison officials should have made a greater effort to accommodate Robert's religious beliefs in the beginning instead of making him choose between two of his religious practices. I understand that the prison had a compelling interest to maintain their regulations for food safety and order, but I do not think that should be held higher than someone’s First Amendment rights. I think the lower courts should rule in Roberts’s favor if the prison cannot justify why they could not accommodate him in 2020. Just because someone is in prison does not mean they lose the ability to practice their religious beliefs freely.
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