In Fowler v. Crawford, 2007 U.S. Dist. LEXIS 53070 (WD MO, July 23, 2007), a Missouri federal district court upheld the denial by officials at a maximum security prison of a Native American inmate's request to have access to a sweat lodge. The court rejected the inmate's First amendment and RLUIPA claims based on the prison's interest in safety and security.
In Stewart v. Corrections Corporation of America, 2007 U.S. Dist. LEXIS 52875 (SD IN, July 19, 2007), an Indiana federal court held that no substantial burden had been placed on plaintiff's exercise of religion either by requiring him to fill out a request in order to obtain vegetarian meals for religious reasons or by taking more than one day to grant the request.
In Horton v. Erwin County Jail, 2007 U.S. Dist. LEXIS 53759 (ED TN, July 23, 2007), a Tennessee federal district court held that a prisoner's conclusory allegation that while in jail he was denied religious exercise is insufficient to state a First Amendment claim.
