In United States v. Broadfield, (7th Cir., June 22, 2026), Brian Broadfield, who had served a prison term on drug charges, sought to have the conditions of his supervised release modified. A condition of his supervised release was that he refrain from all alcohol use. He argued that the condition should be modified so that he can consume a glass of wine each Friday during a Messianic Jewish religious ceremony. Broadfield had previously violated the terms of a supervised release through conduct caused in part by alcohol consumption. The court said in part:
[Broadfield] contends, as a practicing Messianic Jew, the district court’s supervised release condition prohibiting him from the use of alcohol violates his free exercise of religion, in violation of RFRA. ...
Here, Broadfield concedes that the government has a compelling interest in preventing him from using alcohol outside his religious services. But the government goes further, contending that it has a compelling interest in prohibiting Broadfield from consuming alcohol entirely. We agree....
The evidence here shows that completely prohibiting Broadfield from consuming alcohol is the least restrictive means to further the government’s compelling interest in protecting the community from him, preventing his recidivism, promoting his rehabilitation and successful completion of supervised release, and treating his alcoholism. For that reason, we need not opine on whether monitoring Broadfield’s alcohol use with a breathalyzer would be a “viable alternative.”...
