Can Religious Items Be Confiscated in Jail?

  

Everyone has a right to use the items of their choice to practice their religion. But how does this right extend to individuals who are behind bars? This is an issue raised in Goff v. Rode, a case involving Shawn Goff who is an Arizona State Prisoner, and sued four prison officers as well as a complex manager for taking items which he claims violate his freedom to practice religion. Goff is a practicing member of Wicca, which is the largest of the modern Pagan religions. The question the court was looking to answer was not whether or not Wicca is a genuine religion, but instead did the items confiscated substantially burden his ability to practice his religion. 

Goff is 43 years old, and he was sentenced to life in prison for a murder that took place back in 2001. He says that in 2019 he saw guards carrying a plastic bag out of his cell which contained an altar cloth and a medallion. Goff says that he heard the guards describing the items as “satanic” and “devil stuff.” According to Goff however, they were talking about items connected to his religious faith. Goff went on to claim that not having the altar cloth and medallion “deprived him of his sincerely held religious belief.” 

Goff brought forward claims under the free exercise clause of the first amendment while also bringing forward a claim under the Religious Land Use and Institutionalized Persons Act (RLUIPA). RLUIPA gives additional protection for religious exercise by people who are institutionalized, including prisoners. The case began in the U.S. District Court for the District of Arizona where the court decided to grant summary judgement for the defendants, by finding that Goff hadn’t provided enough evidence to establish the necessary violation to the first amendment. Goff appealed and the majority decided that Goff had provided sufficient evidence to create a legitimate argument of whether the confiscation of his religious items created a substantial burden on his religious exercise. They decided that a jury could reasonably conclude that taking away Goff’s medallion and altar cloth substantially burdened his exercise of Wicca. Goff states that these items store energy and are important parts of him performing his rituals. 

There are some things about this case that are important to note. To begin, after the religious items were confiscated, they were never returned. This means that taking these items was substantial and more than just a momentary or temporary confiscation. Another important fact is that Goff had previously gotten approval for these religious items to be in his cell. When these items were taken in a search, they were in a box labeled “religious items” and it is reasonable to assume that the guards knew that these items held religious significance. Although these items were never returned to Goff it is also important to note that these two items were $12 each, and Goff had the option to purchase new ones, however he refused. 

I find Judge Rawlinson’s dissent more persuasive, claiming that taking these items from Goff did not substantially burden his ability to practice his religion. Rawlinson mentions how in order to count as a substantial burden the action in question must put substantial pressure on an individual to modify their behavior or violate their beliefs. Rawlinson claims that even after the confiscation Goff continued to practice daily meditation and prayer. Goff does not say that he cannot afford to purchase the replacement cloth and medallion but instead says that he will not buy them until after he gets his lawsuits taken care of. 

Ultimately, I believe that the confiscation of Goff’s medallion and altar cloth do not violate his free exercise of religion. I think that the emphasis here is on whether or not his ability to practice his religion was substantially burdened. Goff was able to continue practicing Wicca, which has a very wide variety of techniques and methods not relating to the medallion or altar cloth, well after these items were confiscated from him. Additionally, Goff’s refusal to purchase replacements, while still practicing his religion makes it seem as though these items are not necessary for his ability to exercise religion. From my perspective this is important because it shows that the government did not substantially interfere with Goff’s ability to practice his religion. If Goff was still able to practice his religion through prayer, meditation, visualization, and other actions, then taking two relatively inexpensive objects would not rise to the level of a substantial constitutional burden. 

If Goff was to win this case and it is ruled that taking his medallion and cloth provided a substantial burden to his free exercise of religion, then there may be a compelling state interest. In prisons the government has a legitimate interest in controlling property, preventing contraband, and maintaining order in protecting staff and inmates. The issue here however is that this argument falls apart quickly with the idea that Goff had already gotten approval to have these items. If Goff had these approved items in a box clearly labeled as religious material, then it is not a question of whether it was right or wrong to take the items, but instead whether Goff’s first amendment rights to free exercise of his religion were taken from him.

When Can a Public College Tell a Christian Club Who Can't Lead It?

 Should a public college be allowed to strip a Christian student group of its official status because that group insists its leaders actually be Christian? That's the question playing out right now in federal court in Binghamton, New York, where two campus ministries, InterVarsity Christian Fellowship and Campus Bible Fellowship, have each sued SUNY Broome Community College over the same policy.

For years, both groups were recognized student organizations at SUNY Broome. That recognition isn't just a formality. It comes with access to meeting rooms, student activity funding, and the ability to recruit at campus events. Both groups' constitutions require their officers (the students who lead Bible studies, prayer, and worship) to personally affirm the Christian faith. Regular membership, though, is open to anyone, no matter what they believe.

SUNY Broome decided that leadership requirement violated its nondiscrimination policy, which says recognized clubs can't exclude students from leadership roles based on religion. When the groups wouldn't drop the requirement, the college pulled their official status. InterVarsity filed suit in the U.S. District Court for the Northern District of New York on August 21, and Campus Bible Fellowship followed on September 3. Both are represented by religious liberty law firms (Becket for InterVarsity, Alliance Defending Freedom for Campus Bible Fellowship), and both lawsuits argue the college's policy violates their First Amendment rights to free exercise of religion, free speech, and freedom of association.

This isn't totally uncharted legal territory, but it's also far from settled. The closest thing the Supreme Court has said on the subject is Christian Legal Society v. Martinez (2010), which upheld a public law school's "all comers" policy requiring every recognized student group to accept any student as a member or leader, as long as the policy applied the same way to every group on campus. SUNY Broome will almost certainly lean on that case. But the clubs' lawyers point to something important: they claim the policy isn't actually neutral, that other, nonreligious student organizations at SUNY Broome are allowed to restrict their own leadership in ways these Christian groups aren't. If that turns out to be true, this stops looking like a neutral rule applied evenly and starts looking like a policy that quietly singles out religious groups, which is a much harder thing for a public college to defend.

There's also a separate issue worth thinking about: expressive association. A campus ministry exists to teach and model a particular faith. Making it accept leaders who don't share that faith doesn't just affect private worship. It can genuinely change what the group is. That's close to the reasoning the Supreme Court used when it let the Boy Scouts exclude a gay scoutmaster in Boy Scouts of America v. Dale (2000), on the idea that forcing an organization to include certain people can distort its whole message.

Here's where I come down on this. SUNY Broome has a real interest in making sure its recognized clubs aren't discriminatory, but a policy that forces a religious group to accept leaders who reject its core beliefs asks too much. There's a meaningful difference between membership and leadership. No one is being kept out of InterVarsity's meetings or told they can't hear its message or even push back on it. What's being asked is that the people running the group, the ones actually teaching its beliefs, believe what they're teaching. A vegan club shouldn't have to let a committed carnivore lead its cooking demos, and a Christian ministry shouldn't have to let someone who rejects Christianity teach its Bible studies. That's not exclusion for its own sake. It's what the group needs to keep being the thing it is.

The more evidence there is that SUNY Broome enforces this rule unevenly (tolerating leadership restrictions from some clubs while targeting religious ones), the weaker its Martinez defense gets, since Martinez only protects policies that are genuinely neutral and apply to everyone. Courts have sided with religious groups in similar disputes before, including InterVarsity cases at Wayne State University and the University of Iowa. Given that history and what's been alleged here, I'd expect these plaintiffs to have a real shot, though a hearing on InterVarsity's request for a preliminary injunction is still ahead this fall, so nothing is decided yet.

Sources:

Christian Post, "NY college faces another lawsuit from Christian club": https://www.christianpost.com/news/ny-college-faces-another-lawsuit-from-christian-club.html

Worthy News, "Christian Club Sues New York College Over Rule For Choosing Its Leaders": https://www.worthynews.com/117577-christian-club-sues-new-york-college-over-rule-for-choosing-its-leaders

Deseret News, "A New York college said a Christian club must let non-Christians lead prayer. Now they're suing": https://www.deseret.com/politics/2026/09/03/lawsuit-filed-against-suny-broome-over-christian-prayer-group/

Christianity Daily, "Christian Campus Ministry Sues SUNY Broome After Club Recognition": https://www.christianitydaily.com/news/christian-campus-ministry-sues-suny-broome-after-club-recognition.html

Oyez, Christian Legal Society Chapter v. Martinez: https://www.oyez.org/cases/2009/08-1371

Oyez, Boy Scouts of America v. Dale: https://www.oyez.org/cases/1999/99-699

Free Exercise and Equal Treatment in the Hopewell Valley FCA Dispute

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How far should a public school go to make sure it is not promoting religion? That question is at the center of Fellowship of Christian Athletes v. Board of Education of the Hopewell Valley Regional School District. The case involves the Fellowship of Christian Athletes, or FCA, a Christian student organization. FCA argues that the school district restricted outside adult participation in its student group while allowing similar involvement in some secular student organizations. From FCA’s point of view, this means the district treated the religious club differently because of its religious character. The district, however, can argue that it was trying to avoid the appearance that the school itself was supporting or promoting Christianity. This creates a clear tension between the Free Exercise Clause and the Establishment Clause. Public schools cannot establish or promote religion, but they also cannot discriminate against students simply because their activities are religious. The main question is whether giving FCA the same opportunities as other student groups amounts to government endorsement of religion or simply equal treatment. 

FCA’s strongest argument is that the district is not acting neutrally. If adult mentors, volunteers, or guest speakers are allowed in secular organizations but completely prohibited in religious organizations, then religion is being treated differently. The Constitution does not require public schools to give religious groups special treatment, but it also should not allow schools to place extra restrictions on them just because religion is involved. A useful Supreme Court case for thinking about this issue is Board of Education of Westside Community Schools v. Mergens. In Mergens, a public high school allowed several noncurricular clubs but refused to recognize a Christian Bible club. The Supreme Court concluded that the Equal Access Act required the school to give the Christian club the same access as other student groups. An important part of the case is that allowing a religious student organization to meet does not automatically mean that the school endorses its beliefs. That idea seems very relevant here. If students choose to participate in FCA on their own, allowing an adult mentor to attend does not necessarily mean the school supports Christianity. Schools regularly allow clubs to have different viewpoints without officially agreeing with everything those clubs believe.

At the same time, I think the school district has a reasonable concern. This case involves middle and high school students, not adults at a university. Younger students may be more likely to believe that an adult participating in a school activity has the school’s approval. The district also has an interest in making sure that student clubs actually remain student-led instead of becoming controlled by outside organizations. A recent NJ Spotlight article by Seth Siditsky described the dispute as a question of whether the district unlawfully singled out religious clubs or was properly. That concern should not simply be ignored. However, I do not think it justifies a rule that singles out religious clubs. If the real concern is outside adults having too much influence over students, then the district could create one rule that applies to every student organization. For example, all clubs could be required to remain student-led, and outside adults could be limited to advisory roles. The school could also make clear that allowing a club to meet or inviting an outside mentor does not mean that the school agrees with the club’s message.

This is why I think neutrality is the most important part of the case. If the district had a rule saying that no outside adults could participate in any student club, that would be much easier to defend. The rule would apply equally to religious and nonreligious organizations. But if secular clubs are allowed adult mentors while religious clubs are not, then the district may be neutral only on paper and not in practice. The school should be able to set reasonable limits on all student groups, but the rules should not change depending on whether the activity is religious.

This case matters beyond one Christian club in New Jersey because public schools constantly have to balance avoiding government endorsement of religion with protecting students’ private religious expression. Those two goals do not have to conflict. In my view, the best approach is for schools to create clear rules and apply them equally to religious and nonreligious groups. Equal treatment of a religious organization should not automatically be seen as an establishment of religion. Sometimes, it is simply neutrality.

For that reason, I think FCA should prevail if it can prove that secular clubs are allowed similar adult involvement while religious clubs are not. The school has a legitimate interest in avoiding the appearance of endorsing religion, especially because minors are involved. But equal treatment of religious students is not the same as government endorsement of religion. If the same kind of outside involvement is acceptable for other student organizations, then it is hard to justify banning it only for FCA.

Interference with Sacred Land: Gary Perez and Matilde Torres v. City of San Antonio

        For centuries, Native Americans have lived and worshiped at a sacred site near the San Antonio River, in an area now known as Brackenridge Park. Native American artifacts dating back thousands of years have been found in the park, which is also listed on the National Register of Historic Places. However, the City of San Antonio has planned a redevelopment project in this area that would remove heritage trees and deter the nesting of birds such as cormorants. The ecology of this ancient riverbend plays an important role in the religious beliefs and practices of the Lipan Native American Church. Because of this, leaders of the church argue that the city's redevelopment plan would interfere with their ability to practice their religion at the sacred site.

        The City of San Antonio has rejected this claim, arguing that its redevelopment plans do not prevent members of the church from practicing their religion. When the case reached the federal district court, the court required the city to provide the church access to the area for certain religious ceremonies, but it did not stop the planned removal of trees or efforts to deter nesting birds. The court determined that these parts of the redevelopment project did not burden the church's religious exercise significantly. The church leaders disagree, arguing that the environment of Brackenridge Park is essential to their religious practices and cannot be replaced by another location.

        The main constitutional issue in this case involves the Free Exercise Clause of the First Amendment. The government of the United States cannot stop its citizens from exercising their religion and the Constitution protects this. Regarding the case at hand, the constitutional question is whether San Antonio’s redevelopment of Brackenridge Park, which is located on sacred land, violates this protection to practice one’s own faith. This interference with the location and ecology that surrounds it is essential to the Lipan Church and their beliefs. 

        However, the issue is complicated by the fact that San Antonio claims to not be directly interfering or prohibiting the Lipan people from practicing their faith. The city is redeveloping public land that it owns and has good intentions with the project that is currently set to take place. The project is intented to promote the public’s health and safety, who also use this park for a multitude of purposes. As time has gone on, “trees have weakened and died, and bird excrement has greatly increased”, giving the city a logical purpose for removing trees and deterring bird nesting. The plans also include repairing retaining walls, which were constructed while accommodating the Lipan Church’s religious gatherings.

        This begs the question: can religion simply be seperated from the physical envrionment of Brackenridge Park? The trees, birds, river, and surrounding ecology are directly connected to the Lipan people’s religious practices, interfering seems to be a direct misunderstanding of the First Ammendment and its Free Exercise Clause. Telling church members they are free to practice their religion elsewhere shows a lack of accomodation to freedom of religion because there is no equivalent place that can be found. 

        Another important question the case raises is how much authority the courts should have to determine what is necessary to one’s religion. In the Lipan petition, the attorneys argue “courts are not arbiters of theological truth”, meaning that a court’s role is to interpret the Constitution, not to determine whether someone is understanding their own religion correctly. 

        I believe the city of San Antonio’s redevelopment plan violates the First Ammendment of the Constitution. There is a difference between making religious exercise less convenient and destroying something crucial. San Antonio argues that it poses no direct hindrance to the Lipan Church since it is not prohibiting the religious practice. However, if the Lipan people could pick up and practice somewhere else, they would, and evidently tampering with this area would become much less important. Since that isn’t the case and their beliefs need these aspects in touch, there is no fixing the damage that would be done. 

        This should not set precedent for all religious groups to get complete control of public land due to religious practices. This would lead to a slipperly slope in which every religious objection prevents the government from making changes to public property. There has to be a significant justification that a religious practice is tied to a specfic area. San Antonio’s interests in health and safety are legitimate, and while the city may not intend to interfere with religion, the religious importance of Brackenridge Park to the Lipan people cannot be understated.

        With this in mind, the city should be allowed to address legitimate safety concerns, but it should avoid unnecessary interference with the Lipan Church’s religious practices. If less destructive alternatives are available, the city should be expected to consider them.

        Ultimately, this case raises a difficult question about what the “free exercise” of religion actually protects. Religious freedom means little if the government can destroy something necessary to practice one’s beliefs. Courts should respect the Lipan people’s beliefs rather than decide what is important to their religion.

https://firstliberty.org/cases/leaders-of-the-lipan-native-american-church/#simple1

https://law.justia.com/cases/texas/supreme-court/2025/24-0714.html

Public buildings and Religious figures: The Line Between Civic Recognition and Religious Endorsement

Government neutrality toward religion does not always require removing religious symbols from public spaces. On the other hand, the government cannot use public property to favor one religion over others. A recent 2026 case, Fitzmaurice v. The City of Quincy, raised the question of where the line falls between these two principles. The case involves two statues of Catholic saints that Quincy planned to install above its new public safety building. While the statues have clear religious significance, the city argues it selected them because of their longstanding connections to police officers and firefighters. I believe concerns about the statues' size and placement are reasonable, but their Catholic roots alone should not determine their constitutionality. The more important question is whether the city is promoting Catholicism or recognizing symbols with legitimate civic meaning.

The controversy began when Quincy Mayor Thomas Koch commissioned two ten-foot bronze statues of Saint Michael the Archangel and Saint Florian. Saint Michael is traditionally associated with police officers, whereas Saint Florian is the patron saint of firefighters. The Saint Michael statue depicts him with wings, carrying a shield and standing over a demon. In contrast, the Saint Florian statue shows him pouring water over a burning building that houses police, fire, emergency services, and other public offices. The city had already spent more than $760,000 on them, and the final cost was expected to reach about $850,000.

This case became more controversial because most City Council members and the public did not know about the statues until after they had been commissioned. After the plan became public, many residents attended meetings and voiced their concerns. There was, in fact, even an online petition that received more than 1,600 signatures, and several local religious leaders argued that placing Catholic figures on a municipal building would coerce residents of other religions to feel excluded. Fifteen residents eventually sued Quincy under Article 3 of the Massachusetts Declaration of Rights. A lower Court temporarily blocked the installation, and the statues are being kept in storage in the meantime.

In Fitzmaurice v. City of Quincy, the Massachusetts Supreme Judicial Court did not decide that the statues definitely violated the state constitution. Instead, the court upheld the preliminary injunction, finding that the residents were likely to succeed and that the statues should remain in storage while the lawsuit is ongoing. The main constitutional issue is whether Quincy’s plan represents a permissible recognition of symbols connected to public service or government endorsement of Catholicism. There is no general rule that prevents the government from displaying an object merely because it has a religious origin. The problem arises only when the government’s purpose is to give one religion a preferred position.

The residents' strongest argument concerns how the display would appear in practice. Both statues are large, new, and closely associated with Catholic beliefs. They would also stand alone as the only ‘decorations’ in front of a building used by residents of every religion, as well as some with none. Residents represented by the ACLU argue that this would signal government approval of Catholicism. Even if the city’s stated purpose is secular, the display could still lead some residents to believe their government values one faith more than another reasonably. The lack of transparency around commissioning these figures raises doubts that their purpose was entirely civic.

Quincy, however, has a reasonable argument that the statues represent more than something merely Catholic. Saint Michael is commonly used in police imagery, awards, and professional traditions. The Florian Cross appears on fire-department badges throughout Massachusetts, and Saint Florian has become a symbol of courage and sacrifice among firefighters. The city’s attorneys argue that these figures were selected to honor first responders rather than encourage Catholic worship. No visitor would be required to pray, participate in a religious ceremony, or merely accept Catholic worship. From this perspective, the government is recognizing the professional importance of the figures rather than endorsing their religious meaning.

The court relied on Colo v. Treasurer & Receiver General, which explains that questions involving religion and government require consideration of history, purpose, effect, and political divisiveness. These factors support both sides. The statutes have a secular purpose because they honor police officers and firefighters, but their isolated placement could create the effect of religious endorsement. History also matters. In American Legion v. American Humanist Association, the Supreme Court allowed a cross-shaped war memorial to remain on public land because it had developed a commemorative meaning beyond its religious origin. The Quincy statues are new, but the Saints' connection to first responders is long-standing in American history. Therefore, the statues' age should be considered alongside the history of the traditions they represent.

The use of public money also deserves attention. Quincy paid for the artwork directly, but the money did not go to the Catholic Church, fund worship, or support religious instruction. The statues would remain as city property; this differs from the government directly financing a religious organization, although the city is still responsible for the message communicated by artwork it selects and purchases. Because this is government speech rather than private religious expression, Quincy must make sure the display does not suggest that Catholicism has an official or preferred status.

The court acted reasonably by keeping the statues in storage while it examined the case more fully. However, that temporary decision should not automatically lead to a permanent prohibition. If Quincy can show the statues were selected for their professional meaning and clearly explain that purpose through a plaque or a broader public-service display, their religious origins should not make them unconstitutional. Religious neutrality is better protected when the government neither promotes a particular faith nor excludes a civic symbol solely because it connects to religion.

Freedom and Funding: Wollard v. Thurmond

The protection and consideration of the First Amendment becomes particularly challenging when trying to determine religious freedom and expression’s place in public schools (and if there should even be any in the first place). This tension is at the center of Woolard v. Thurmond, in which a group of parents at two California charter schools, Visions in Education and Blue Ridge Academy, filed a lawsuit against the two schools, as well as various of their officials, in October of 2023 claiming the schools refusal to buy religious curricular materials and instructions was an unconstitutional discrimination against religion and a breach against their rights pertaining to the Free Exercise Clause. For context, in 1992, California began allowing the establishment of charter schools, these being public schools that are funded with public money, but are run by individuals. It is important to note, however, that while some charter schools are in-person, both Visions in Education and Blue Ridge Academy are not, meaning that parents play an integral part of their children’s education. To this point, as parents primarily homeschool their children, aside from a handful of online classes, the plaintiffs claim is that they should have some agency over the curriculum and the materials they should be allowed to request and in turn, teach to their children, in this case this being religious material. This being said, while the parent’s perspectives were acknowledged, their requests were denied by the schools based upon California state rules that provide: “sectarian or denominational doctrine shall not be taught, or instruction thereon be permitted, directly or indirectly, in any of the common schools of this State,” subsequently bringing on the lawsuit. 

After being rejected by the U.S. District Court for the Eastern District of California, this case was brought to the U.S. Court of Appeals for the Ninth Circuit, where on September 11, 2025, the Ninth Circuit upheld the district court’s decision to reject the plaintiffs argument on the basis that the plaintiffs had no ground on which they can demand religious material to be provided as part of their education in public schools that are paid for with taxpayer money. Specifically, the plaintiffs' claim of religious discrimination and an infringement upon their freedom of exercise was rejected by the courts as they, nor their children, were being “categorically excluded” from any public benefit. Rather, California’s public schools were required to provide a secular education, meaning that the plaintiffs were not being denied any public benefit because of their religion, and that ultimately California’s laws on public school education were neutral, and therefore, non-discriminatory. With this reasoning, ultimately, the courts rejected the parents' arguments under the First Amendment’s Free Exercise Clause. 

The central question being raised in this case is whether a public school violates the First Amendment’s Free Exercise Clause when it refuses to buy proposed religious educational material to religious students and educational facilitators, simply because the materials are religious? Personally, I do not think public school boards refusing to buy religious material to be taught is a violation of the Free Exercise Clause. Continually, while I do agree with and support the courts Free Exercise reasoning, and agree with their ruling to reject the parents' lawsuit, I think there is also another First Amendment concern that the courts surprisingly did not address. This being if they did support the parents’ argument, publicly purchasing religious material for one's curriculum could potentially pose a violation of the Establishment Clause. Regardless of this, however, I think the most compelling argument made by the courts is that of neutrality, as making sure public education remains secular in all capacities helps ensure that the government is not endorsing or establishing any religion.

This being said, I do understand the perspective of the parents in this case, as they are the ones teaching their children. In this context, the parents weren’t asking public school teachers to promote any sort of religion, or teach it in schools, they were parents in independent study programs who held a major responsibility for educating their own children. I think there is an important distinction between the government teaching religion in public schools and an individual, religious family being allowed to use religious materials within a public school system. 

Nevertheless, as I mentioned before, while there is this distinction, the main point is that the programs are funded by the public, and an extension of government speech, and in my opinion this outweighs the parents’ free exercise argument. In the end, public funding matters because the parents are not asking to teach religion to their children privately, or separately from the state provided curriculum, they are asking to be provided the religious materials as part of the education provided to them by the state, which is, in my opinion, a possible establishment of religion, and not a violation of their ability to exercise their religion, as they are not being prevented from purchasing and using religious materials independently of the government supported and supplied curriculum.

Is the VTAG Program Exclusive? Bethany Hall v. A. Fleming

    The state of Virginia offers a Virginia Tuition Assistance Grant Program (VTAG). This grant is a non-need based grant that can be awarded to Virginia residents attending accredited Virginia colleges and universities. The only requirement for this grant is being a full time student and Virginia resident. However, in the fine print for being able to hold this grant lies an additional factor of how the grant can be used for education. Stating it’s, “...primary purpose is to provide collegiate, graduate, or professional education and not provide religious training or theological education”. This is where Bethany Hall, a student at Liberty University in Virginia, feels as though her rights have been violated.

    Hall, who was a recipient of the VTAG grant and who was driven by her faith, changed her major from Elementary Education to Youth Ministries. This caused the VTAG grant to be revoked from her. Because she relied on this grant to help pay her tuition, she again, changed her major to Music and Worship, and was once again, denied by VTAG to receive the grant because of the religious nature of her major. 

    Hall claimed that this violated her Free Exercise Rights under the Constitution's First Amendment. Hall, however, has run into trouble with moving her case forward because of the precedent established with Locke v. Davey, where a precedent was established in 2004 stating that a state does not violate one’s First Amendment rights when it provides funds to secular college majors but not religious ones. Joshua Davey filed suit after his scholarship was taken away after he had chosen to pursue a major in theology. He believed that the ban on him being able to be awarded scholarship money because of choosing to pursue a major surrounding religion violated his First Amendment Right to his Free Exercise of Religion. The court stated that this law does not violate free exercise as states have always historically had an interest in not providing public funds for religious activity. Since 2004 Locke v. Davey  has been used as precedent for several cases surrounding the issues of public scholarship funds and free exercise rights; Hall wishes to overturn the ruling for this case and to establish a new precedent for cases such as hers. 

    One of Hall’s attorneys, Jeremy Dys, has stated that, “Excluding students from a state scholarship or grant simply because their choice of major is religious is discriminatory”, which calls into the main issue of this case, can the state of Virginia revoke and withhold earned public grant money because the college or university student has chosen to pursue a religious major?

    Although this case, at face value, does seem to be infringing on Hall’s Free Exercise rights, upon further research of the VTAG program and Liberty University’s major offerings, this may not be the case. Liberty University is an evangelical Christian university which offers a variety of religious studies majors and programs, and some of these majors are eligible to be studied and have a VTAG grant. These include: 

-Christian Studies

-Global Studies

-Philosophy and Religion

-Religion

-Religion: Evangelism

-Religion: Christian Counseling

-Religion: Christian Counseling

-Religious Studies: Global Studies

-Religious Studies: Old Testament 

-Religious Studies: Theology and Apologetics 

-Religious Studies: Jewish Studies

    The ineligible programs, although a greater amount than the eligible programs, all include some form of worship, leadership, and ministry components. VTAG is not explicitly denying students who wish to participate in religious studies the right to the grant, but students who wish to study, in short, the proclamation of the Christian faith.

    Although some students would not be able to pursue exactly what they are wishing to pursue through the VTAG program, their First Amendment rights are not being infringed upon because of this requirement with VTAG. Public funds should not be explicitly used to support the proclamation of any faith. In the case of many of the majors excluded from VTAG studies of how to teach and spread the Christian faith are included. Religious majors are not explicitly ineligible for VTAG, they are simply narrowed down so that public funds are not provided to students so that they can then proclaim a religion. If students were able to receive state funds to study ministry, for any religion, it could be perceived as a state supporting a religion and violating the Establishment Clause, which states that there should be no law that respects the establishment of religion. 

    Though the VTAG requirements seem to separate students that wish to procure religious degrees from those wishing to earn secular degrees, upon further investigation it seems that Free Exercise of religion is respected through these requirements, and ultimately, the Establishment Clause is what is being protected through the decision to deny public funds to ministerial based university majors.

Proof, Power, and Procedure: Taking a look at Arroyo Castro v. Gasper

Imagine a public-school teacher placing a small crucifix on her classroom wall. For the teacher, it is a personal reminder of faith; for others, it may signal a religious message from the school. This tension is central to Arroyo-Castro v. Gasper, a recent Connecticut case that has attracted national attention. It raises a difficult constitutional question: When does a public-school employee’s personal religious expression become government-sponsored religious expression? The answer could have nationwide implications as public schools try to balance respect for individual religious freedom with government neutrality.

In the fall of 2024, Marisol Arroyo-Castro, a seventh-grade social studies teacher in New Britain, Connecticut, hung a crucifix that was one foot tall and six inches wide on the classroom wall near her desk. In December 2024, school administrators instructed her to remove it or place it somewhere students could not see it. They were concerned that a visible religious symbol in a public-school classroom could create the perception that the school was endorsing religion. Arroyo-Castro refused to remove the crucifix, saying it has personal and religious meaning to her. 

The school district disciplined Arroyo-Castro and, in a letter, said the Establishment Clause prohibits public school employees from placing religious objects in a classroom. The school district also said the crucifix had no curricular purpose. Arroyo-Castro challenged the school district’s actions in federal court, alleging violations of her First Amendment right to Free Exercise of religion and free speech. She also asked for a preliminary injunction to reverse the school district’s decision and allow her to keep the crucifix on the wall. In November 2025, the federal district court denied Arroyo-Castro’s request for a preliminary injunction. She appealed to the Second Circuit. 

At the center of this case is a disagreement about how to characterize the crucifix. Arroyo-Castro views it as a form of religious expression protected by the Free Exercise Clause, while the school district views it as a religious symbol in a public classroom that violates the First Amendment’s prohibition on government establishment of religion. This distinction places two First Amendment principles in tension: protecting an individual’s religious exercise while preventing government endorsement of religion.

Arroyo-Castro’s position that displaying the crucifix expresses her religion and should not automatically become government speech simply because she works for a public school draws support from Kennedy v. Bremerton School District (2022). In that case, the Supreme Court held that the Free Exercise and Free Speech clauses of the First Amendment protected a public-school football coach’s right to kneel and pray midfield after football games. Arroyo-Castro can similarly argue that her crucifix represented her beliefs, not the school’s. If teachers can display family photographs, sports memorabilia, or inspirational messages, restricting a religious object specifically because it is religious raises concerns about unequal treatment. She also did not require students to pray or teach Christianity as part of the curriculum, making her display seem more personal than governmental.

The school district and Freedom From Religion Foundation (FFRF), however, argue that the issue is not simply whether Arroyo-Castro can practice her religion. Public schools also have an obligation to avoid government promotion of religion. A classroom differs from an ordinary workplace because teachers have authority over students, control the classroom environment, and communicate to students who cannot simply choose to leave. FFRF argues that the crucifix was displayed in plain view alongside classroom-related materials and that Arroyo-Castro’s classroom displays were connected to her official responsibilities. From this perspective, allowing teachers unrestricted religious displays could blur the line between personal faith and government-sponsored religion and make students reasonably perceive a religious message as carrying the authority of their public school.

What makes Arroyo-Castro particularly difficult is that both sides claim to be protecting religious freedom. Arroyo-Castro argues that requiring her to hide a symbol of her faith burdens her Free Exercise rights. The district argues that it is protecting students by preventing a government classroom from appearing to promote one religion. The constitutional question of whether the government can protect against an Establishment Clause violation by restricting an employee’s Free Exercise rights has even drawn the U.S. Department of Justice into the dispute. It argues that the district court incorrectly classified the crucifix as government speech and gave too much weight to Establishment Clause concerns. Ultimately, a lot depends on whether the crucifix is understood as Arroyo-Castro’s personal expression or as part of her official role as a teacher.

I believe Arroyo-Castro has the stronger constitutional argument, though her right to religious expression is not unlimited. The Establishment Clause should not mean that religion must become completely invisible whenever someone works for the government. Instead, context should determine when personal expression becomes government promotion. If Arroyo-Castro had led students in prayer, encouraged them to accept Christianity, pressured them to participate in religious activities, or incorporated her beliefs into instruction, the district would have a much stronger reason to intervene. A personal crucifix near her desk, however, does not necessarily communicate the same message. Equal treatment also matters. If teachers can personalize classrooms with secular objects reflecting their identities and beliefs, but religious objects are excluded specifically because they are religious, government neutrality risks becoming unequal treatment. True neutrality should mean treating religious and nonreligious personal expression equally while still preventing teachers from using their authority to promote or impose religious beliefs.

Arroyo-Castro v. Gasper ultimately asks where public schools should draw the line between preventing religious endorsement and protecting employees’ religious freedom. Teachers should not have to completely hide their religious identities because they work for the government, but they also cannot use their authority to impose beliefs on students. The Constitution should protect personal religious expression while allowing schools to intervene when it becomes promotion or coercion. How the Second Circuit draws that line could influence how public schools approach religious expression by employees of many different faiths.

Hiester v. School District of Philadelphia: When a Prayer Room Crosses the Constitutional Line

        Public schools must balance two important constitutional principles when addressing religion. They are required to allow students to freely practice their religion while also preventing actions that favor or establish a particular religion. A recent case, Hiester v. School District of Philadelphia (2026), raises questions about what the line is between these two principles. The case involves a prayer room at the Academy at Palumbo, a public high school in Philadelphia, that the plaintiffs claim was effectively reserved for Muslim students. While providing students with a place to pray and practice their religion can be seen as a reasonable religious accommodation, I believe the school crossed the constitutional line because it restricted the room to Muslim students and used public resources to support one religion over other religions.

        The controversy began on June 11, 2024, when M. Danowitz, a former Jewish Palumbo student, visited some friends at the school. Danowitz, John Hiester, and Meru Parmar eventually entered a room in the school library labeled as the "Quiet Room". Inside, however, they found Islamic decorations, Arabic signs, a “Happy Ramadan” message, and guidelines from the school’s Muslim Student Association all over the room. Danowitz recited a short Jewish prayer in Hebrew, saying he was a proud Zionist, and did a handstand at the end of the prayer. Before leaving the room, he also removed a laminated placard from the wall and then placed it on the floor.

        The situation quickly became more escalated. Rumors were being spread that the students had trashed or damaged the prayer room and/or harassed the Muslim students that were present. Hiester received threatening messages, and school administrators began investigating what they described as a potential hate crime incident. Hiester and Parmar were eventually suspended, and the plaintiffs claim that the school disciplined them because, as non-Muslims, they entered a space that had only been designated for Muslim students and no one else. The families eventually sued the School District of Philadelphia and several school officials after the incident. In Hiester v. School District of Philadelphia (2026), the federal district court did not decide that the school had definitely violated the Constitution. Instead, they found that the students had made a plausible Establishment Clause claim that could continue rather than being rejected.

        The main constitutional issue seen is whether the school was simply accommodating Muslim students’ religious exercise or whether it was actually favoring Islam in violation of the Establishment Clause. There is nothing actually wrong with a public school allowing students to use a room to pray. Students do not lose their ability to practice their religion simply because they attend a public school either. The real problem arises if the government goes beyond providing equal opportunities for religious exercise and begins giving special treatment to one specific religion.

        The court relied on Hilsenrath v. School District of the Chathams (2025), a similar case, which explains that government action can violate the Establishment Clause. Two characteristics in this case were particularly important. One was restricting the participation of religious dissenters and providing government financial support in a way that favored only one religion. The court found it reasonable that Palumbo officials suspended the students for entering the Muslim Prayer Room as non-Muslims and also reinforced that the organization and the way things looked within the room were available only to Muslim students. 

        I believe this is where Palumbo crossed the constitutional line. If the "Quiet Room" was genuinely available to students of all religions at the school, then allowing Muslim students to pray there should be considered a reasonable accommodation of their religious exercise. However, if school officials allowed it to become a Muslim-only space and then punished non-Muslim students for entering it, the school was no longer acting in neutral way towards each religion and that's when this situation became an issue. The government does not need to remove religion from public schools in order to comply with the Constitution, but it should not decide that one religious group deserves privileges that others do not receive, therefore it does not make all religious groups equal.

        Ultimately, I personally believe public schools should accommodate and help religious exercise without promoting or privileging a particular faith. The actual prayer room at Palumbo was not necessarily a constitutional problem in my opinion. The more important issue was how that room was actually “operated”. Religious freedom is better protected when students of every faith have equal opportunities, because that is when not every faith and religion is equal.

When Safety Limits of Religious Freedom: Chase Hadez and the Celestican Church of Christ

Chase Hadez, more commonly known as Colton Lexus, filed for emergency occupation of his self-constructed “tiny-home” or “POD Structure” on August 28, 2026 after the city of Springfield, Illinois deemed it unsafe for human occupation. As Hadez explains in his attempt to appeal the city’s injunction, his order to vacate his home violates Free Exercise of the US Constitution, as he claims that it is his “calling from God” to live in this austere manner, as he is an “adherent of the Celestican Church of Christ,” and  “holds sincere religious beliefs that require him to ‘live off-grid and faith-based tiny-home or POD structure on real property that he owns or controls.’” 

For context, his home stands at 18 square-feet large, on “a corner lot at 17th and Carpenter streets.” As alluded to above, he crafted the structure himself from watching how-to videos on YouTube, and it features solar panels, battery-powered generators, a foundation of heavyweight tires, air conditioning, insulation, a six-foot bed, a microwave and an internet connection from a cheap satellite service.” That said, the house cannot seem to pass code set in place by the city of Springfield in order to ensure the safety and health of its constituents. Some of the grounds that make it “unfit for human habitation”  are as follows: it lacks running water, a sewage or septic system, access to electricity, and other utilities that promote the safety of an inhabitant. 

Hadez argues that the order to vacate the home is a clear violation of his right to freely exercise his religion, as guaranteed by the US constitution. It is important to note that Hadez views his home as an official place of worship. As he claims his home is central to his religious beliefs as a member of the Celestican Church of Christ and was “called upon by God” to create and dwell in this home, he believes that his house not only should be exempt from city zoning laws as it falls under the by the Religious Land Use and Institutionalized Persons Act (RLUIPA). This act was intended to “protect individuals, houses of worship, and other religious institutions from discrimination in zoning and landmarking laws.” Not only that, if he is not free to be in his home, he believes that the city of Springfield is violating his right to Free Exercise of his religion The court order explains that he “ contends that enforcement of the order requires removals of the unit, which violates violates the plaintiff’s rights to worship in his home and substantially burdens his free exercise of religion”  In his own words, he iterates that the city of Springfield is “unjustly harassing [him].” 

The official court order explains that Hadez argues that the forced removal of his home on account of zoning and code issues should be repealed as his house is “used for worship,” which makes it exempt from zoning laws according to the Religious Land Use and Institutionalized Persons Act (RLUIPA). Overall, he argues that  “by enforcing the state court injunction, [the] City’s actions deprive him of personal property and liberty interests without due process of law in violation of the 14th amendment. Additionally, he contends that the City’s land-use regulation and injunction impose a substantial burden on the plaintiff’s religious exercise in violation of the Free Exercise Clause of the Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).” The RLUIPA ultimately “protect[s] individuals, houses of worship, and other religious institutions from discrimination in zoning and landmarking laws” 

In my opinion, I do not believe that Chase Hadez should be granted religious exemption from Springfield’s zoning standards. Firstly, I doubt his claim to “sincerity” of the religious cause of the Celestican Church of Christ. After extensive googling, I cannot seem to find any information explaining this religion or confirming it exists beyond merely himself as an individual. That said, for argument’s sake, even if the Celestican Church of Christ is an earnest religion and Chase Hadez is truly sincere in the belief that God has called upon him to create and live in a very… austere… home, I still believe that the City of Springfield is correct in its condemnation of the home. As the zoning laws’ primary function is to protect the safety of the residents of Springfield, a compelling interest of the state, the zoning parameters should supersede his claim of exemption due to the RLUIPA. Moreover, the degree of unsafety of his home, in my opinion, poses a relevant threat of danger, and I believe that it is just that it is deemed uninhabitable. Because the “religious space” of his tiny home doubles as both a place of worship, and more importantly, a home, the city of Springfield undoubtedly has the authority to ensure that he cannot continue living in this home. 

Therefore, if he continues to be granted appeals, the court should undoubtedly rule against him. As the order to leave his home is not an attack on his religion but merely a means to protect him, it is not a violation of the right of Free Exercise. However, if his adherence to the Celestican Church of Christ were to be deemed sincere, I do believe that this space can still be used to worship his religion, but not be able to act as his residence. If it truly is a religious space, it should in fact be protected and exempt from zoning laws. Hence, while Chase Hadez, an alleged member of the Celestican Church of Christ, claims the condemnation of his “austere home” limits his right to freely exercise his religion, the decision of removal from his home by the City of Springfield should be upheld, as the unsafety of his home poses a threat of danger, and is a compelling interest of the state. 

Sources: 

http://religionclause.blogspot.com/2026/09/compliance-with-building-code-does-not.html

https://cases.justia.com/federal/district-courts/illinois/ilcdce/3:2026cv03224/100310/11/0.pdf?ts=1788191766

https://www.justice.gov/crt/religious-land-use-and-institutionalized-persons-act

https://www.illinoistimes.com/news/tiny-house-owner-has-his-day-in-court/