In Keith v. Estelle Unit High Security Administration, 2006 U.S. Dist. LEXIS 93014 (SD TX, Dec. 22, 2006), a Texas federal district court rejected a free exercise claim by an Texas inmate who complained that he was not permitted to purchase candles and matches needed to practice Satanic rituals, and was refused assistance in locating nearby churches or groups associated with Satanic worship.
In Nellis v. Jahnke, 2006 U.S. Dist. LEXIS 92965 (ED WI, Dec. 21, 2006), a Wisconsin federal district court permitted a Native American prisoner to move ahead with his free exercise claim against prison officials. The inmate's complaint alleged that he had been denied "chapel studies", the only means of practicing his religion, after he quit his voluntary employment with the prison's food service department out of fear that co-workers would harm him.
