Accommodation of Prisoners With Idiosyncratic Religious Beliefs
Under O’Lone v. Estate of Shabazz, 482 U.S. 342 (1987), prison officials may restrict inmates’ religious practices, but such restrictions are constitutionally limited to those that reasonably relate to legitimate penological objectives. The Religious Land Use and Institutionalized Persons Act offers additional, statutory protections. But talk of a religious practice normally conjures up the image of an organized religious group acting pursuant to shared beliefs. What are we to make of an inmate who seeks an accommodation based on an indiosyncratic “religious” belief that is not actually espoused by his or her sect? Must an inmate’s belief be officially supported by an organized religious group in order to receive legal protection?
Yes and no, the Seventh Circuit answered last week in Vinning-El v. Evans (No. 10-1681).

