## Facts

- New Jersey prison officials adopted two measures affecting certain inmates assigned to outside work details: (1) a rule requiring them to work outside the buildings where Friday Jumu’ah services were held and (2) a policy barring return to those buildings during the workday.
- Muslim inmates alleged the measures prevented attendance at Jumu’ah, a weekly congregational service required by their faith at a specified time on Fridays.
- Prison officials justified the measures as responses to overcrowding and as serving security, order, and rehabilitative goals, including reducing congestion at a high-risk gate area and simulating work conditions in the community.
- The federal district court, after a bench trial, upheld the policies as reasonable and found no constitutional violation.
- The Third Circuit vacated and required the State to show both a security justification and that no reasonable accommodation method existed without creating bona fide security problems.
- The Supreme Court granted review.

## Issues

1. What standard governs First Amendment free-exercise challenges to prison regulations that burden inmate religious practice.
2. Whether prison officials must prove that no reasonable alternative method exists to accommodate the religious practice without creating security problems.
3. Whether the challenged work-assignment and movement restrictions violated the Free Exercise Clause.

## Decision

- The Supreme Court reversed the Third Circuit.
- The Court held the Third Circuit applied an incorrect, insufficiently deferential standard by shifting to prison officials the burden to disprove alternative accommodations.
- Applying the prison-regulation standard that a restriction is valid if reasonably related to legitimate penological interests, the Court upheld the challenged policies.
- The Court found a rational connection between the restrictions and legitimate interests in security, institutional order, and rehabilitation.
- The Court emphasized that inmates retained other avenues for religious practice (e.g., participation in other Muslim observances and access to a chaplain, study groups, and a special diet).
- The Court rejected a least-restrictive-means approach in this context and declined to require prison administrators to rebut every conceivable accommodation proposal.

## Legal Principles

- A prison regulation that impinges on inmates’ constitutional rights is valid if it is reasonably related to legitimate penological interests.
- Courts must give substantial deference to prison administrators’ judgments in matters of security, order, and allocation of institutional resources.
- In applying the reasonableness inquiry, relevant considerations include: (1) a valid, rational connection to a legitimate governmental interest, (2) alternative means for inmates to exercise the asserted right, (3) the impact of accommodation on guards, other inmates, and prison resources, and (4) whether obvious, easy alternatives show the policy is an exaggerated response.
- Prison officials are not required to prove the nonexistence of reasonable alternative accommodations, and the Free Exercise Clause does not impose a least-restrictive-means requirement on prison regulations reviewed under this standard.

## Conclusion

The Court held that prison policies preventing certain Muslim inmates from attending Jumu’ah did not violate the Free Exercise Clause because they were reasonably related to legitimate penological interests, and the Constitution does not require prison officials to prove that no reasonable accommodation alternatives exist.


O'Lone v. Estate of Shabazz, 482 U.S. 342 (1987)