In Heleva v. Kramer, 2006 U.S. Dist. LEXIS 5237 (MD Pa., Jan. 27, 2006), a Pennsylvania federal district court held that an eight month delay by prison officials in getting to a prisoner two spiritual self-help books shipped to him in jail had not adversely impacted his sincerely held religious beliefs.
In Meggett v. Pennsylvania Dept. of Corrections, 2006 Pa. Commw. LEXIS 66 (Commonwealth Ct., Feb. 13, 2006), a Pennsylvania state court upheld the state prison system's regulations on hair length and styling against a prisoner who wished to wear dreadlocks as part of his Hebrew Israelite faith. The court held that while a practice is protected even when it is not a mandatory tenet of a religious faith, here the policy was a reasonable response to legitimate penological concerns.