In Adams v. Correctional Emergency Response Team, (3rd Cir., April 26, 2021), the U.S. 3rd Circuit Court of Appeals affirmed the dismissal of an inmate's complaint that his religious necklace was confiscated in violation of the 1st Amendment, saying in part:
The complaint stated only that the missing necklace reflected Adams’s religious faith, with no description of how losing it affected his religious practice.
The court also held that RLUIPA does not permit actions against state officials in their individual capacities.