In Robins v. Wetzel, (3d Cir., Sept. 28, 2022), the U.S. 3rd Circuit Court of Appeals vacated the dismissal of a portion of a Pennsylvania federal district court opinion in a suit in which an inmate challenged the sex offender treatment program that was required for his release on parole. The program required him to admit his guilt. According to the court:
Although he was willing to admit that he engaged in sexual relations with his wife, who was a minor child at the time, he was unwilling to admit that that conduct was illegal....
He contended that:
[M]arriage was a sacred tenet of his religion, and he could not admit the illegality of his sexual conduct, which he construed as denouncing his religious marital vows, without violating his religious beliefs.
The court held:
[T]his Court has not had occasion to consider an acceptance-of-responsibility component of a sex-offender treatment program in the context of RLUIPA or RFRA. Given the lack of controlling precedent, we ... remand for the District Court to address the RLUIPA and RFRA claims in the first instance.
