Cutter v. Wilkinson

The Religious Land Use and Institutionalized Persons Act (RLUIPA) barred the government from imposing a substantial burden on prisoners' religious exercise. Five Ohio inmates-adherents of non-mainstream faiths including Asatru, a white-supremacist church, Wicca, and Satanism-sued, alleging the prison failed to accommodate their religious exercise in violation of RLUIPA. Prison officials countered that RLUIPA improperly advanced religion in violation of the Establishment Clause.

Whether the government may, consistent with the First Amendment, reasonably accommodate the religious exercise of institutionalized persons without establishing religion.