In Childs v. Webster, (7th Cir., March 4, 2026), the U.S. 7th Circuit Court of Appeals held that there was not a violation of a Muslim inmate's free exercise rights under RLUIPA or the 1st Amendment when his prison refused to distribute corrected prayer-time schedules to Muslim inmates. Inmates were allowed to purchase corrected schedules with their own funds or by outside donations. Prison policies bar use of taxpayer funds to purchase inmate personal property items. The chaplain had originally made printed schedules available at prison expense to inmates in the chapel, but those schedules turned out to be inaccurate. The court said in part:
The de minimis cost of purchasing a prayer schedule does not rise to the level of a “substantial” burden on religious exercise. Such a “truly negligible” and “unquestionably affordable” financial burden could not realistically coerce Childs to violate his sincerely held religious belief..... Absent a true coercive dilemma, to conclude that Childs’s claim still satisfies the “substantial burden” requirement of RLUIPA would give the word a meaning it cannot bear and render Congress’s choice of the word “substantial” meaningless surplusage.... And because Childs failed to carry his initial burden of persuasion, the government is not required to justify its policy under strict scrutiny....
... [P]rison policy, which does not permit the purchase of personal property for inmates, religious or secular, is a neutral and generally applicable rule that does not violate the Free Exercise Clause...
