In Erdahl v. Pirc, (8th Cir., Nov. 18, 2021), the U.S. 8th Circuit Court of Appeals held that a Buddhist inmate's religious exercise was not substantially burdened by denying him separate Soto Zen religious services. He already can attend existing Buddhist services conducted by the minister he wanted for his separate services. The court concluded:
In the end, the prison only has to provide “a reasonable opportunity” for Erdahl to practice his faith.
